Recovery of Interest From the IRS That Would Otherwise Be Forfeited

Ashland offers a highly-trained technical team of Complex Interest Examiners who have spent many years with the IRS complex interest team in Ogden, Utah. Our knowledge of account analysis and understanding of internal IRS policy, procedures, and interpretations, is a sure way to claim all of the interest that your company can recover. 


Our Complex Interest Examiners know case law, and have a real working knowledge of account analysis which includes an understanding of internal IRS policy and interpretations. Using the same software the IRS currently uses to perform complex interest calculations, our team can work directly with the IRS computational examiner to resolve any issues prior to the final interest determination, which can save you from filing claims.


  • IRS Settlement Services

    Whether your case is solved at the appeals level, settled before trial or settled with a decision from the Court of Appeal or Tax Court, it is likely that the interest calculations offered by the IRS do not take into account all of the favorable adjustments that can be made. Interest adjustments made by the IRS typically are related to the settlement amounts and do not take into consideration adjustments available in other years or other types of tax.

    By working with Ashland as you near a settlement, our specialists can order detailed transcripts and not only provide calculations for the amounts that are being settled as a verification, but also provide information on offsets and additional interest that may be available to be claimed. Submitting favorable adjustments to the IRS at this point, eliminates the need to file a later claim for refund.

  • Account Analysis & Recovery Review.

    An account analysis can identify single module adjustments and netting opportunities for several types of taxes, covering as much as 20 years in some cases. Many taxpayers don't realize the statute for interest is longer than the normal statute of limitations for federal taxes. Ashland can conduct a comprehensive account review of all years (that have not been sent to retention) and all types of taxes (income, excise, employment and other types of taxes) with only a request for detailed records.

  • Global Interest Netting

    Recent court decisions have expanded the meaning of "same taxpayer" by allowing Global Interest Netting between parents and their subsidiaries with different taxpayer identification numbers. Ashland has been at the forefront in this area. A landmark case by one of the money center banks was recently decided that defined which entities could take advantage of "netting" between related entities. Ashland's technical staff has provided the complex interest calculations for the plaintiff in this case since it was filed. Because of this in-depth knowledge of the IRS positions, our technical team is able to assist other companies that may be considering this as a recovery option.

  • Litigation Support

    Ashland provides complex interest calculation support to legal teams throughout the country representing major taxpayers during federal tax litigation. As former members of the IRS Complex Interest Team in Ogden Utah and Revenue Agent Supervisors, the Ashland team has the skills to perform the calculations quickly and accurately to enhance your negotiations with the IRS. We utilize the same software as used by the IRS and can work directly with the IRS interest agent to resolve any differences. This service is typically done on a time and material basis.

Senior Team Members

The Ashland Federal Interest Team is made up of former senior-level IRS professionals from the IRS Complex Interest Unit. Our team has the expertise and experience to identify all opportunities to recover overpaid interest from the IRS for SMB and Enterprise organizations. We have been computing interest using netting for many years.  Our knowledge is unsurpassed in this complex area of tax law, IRS regulations, and procedures, making the recovery process much easier.

Mike Marr

The Ashland Federal Interest Team is made up of former senior-level IRS professionals from the IRS Complex Interest Unit. Our team has the expertise and experience to identify all opportunities to recover overpaid interest from the IRS for SMB and Enterprise organizations. We have been computing interest using netting for many years. Our knowledge is unsurpassed in this complex area of tax law, IRS regulations, and procedures, making the recovery process much easier.

Robert Ellis

Robert Ellis provides evaluation and resolution services for complex restricted federal interest issues, including global interest netting. During his 20 year tenure with the IRS, He spent over 10 years as a key member of the IRS’s Ogden Complex Interest Calculations Group. Following his work with the IRS, he has worked with corporate clients providing interest calculation services. Robert has unique experience that makes him a valuable resource for our clients. His insider knowledge of IRS processes, transcripts, and technical positions have allowed him to successfully prepare and file refund claims for interest totaling hundreds of millions of dollars.