[1]"Pennies on the dollar" claims before reviewing the case
[2]IRS impersonation (logos, language, implied affiliation)
[3]"Government certified" / "IRS approved" / "IRS partner"
[4]Upfront fees for debt relief / tax resolution (TSR)
[5]Guaranteeing specific settlement amounts or refund sizes
[6]Threats about IRS action to pressure prospects
[7]Fabricating testimonials or results
[8]Using client tax data for marketing without §7216 consent
[9]Marketing texts without express written consent (TCPA)
[10]Ignoring the Do Not Call registry
[11]Failing to disclose negative consequences of resolution
[12]"IRS Certified Tax Professional" (this title does not exist)
Sourced from FTC enforcement actions 2023–2026, incl. FTC v. American Tax Service (June 2, 2026): $77.7M judgment, operators banned for life. Core violations: IRS impersonation, pennies-on-dollar claims, fictitious add-on upsells, upfront fee collection.