For Enrolled Agents and tax resolution firm owners
How to Vet Tax Resolution Leads Before You Pay
Buying tax resolution leads? Five questions to ask a vendor, what TCPA consent records to demand, and which terms to put in writing before you pay.
If you are shopping for tax resolution leads, ask every vendor five things before any money moves. Who else receives this lead? Can you show the consent record for this specific person? What exactly counts as a qualified lead and a booked appointment? What do you refund, and when? What does one retained case cost your firm at the end, not one lead? A vendor who answers all five in writing is worth a small paid test. A vendor who gives those answers on a sales call but will not put them in the agreement has not committed to any of them.
This guide is for Enrolled Agents and resolution firm owners who already take IRS cases and are deciding whether to buy leads at all. It does not rank vendors or say anything about any vendor's conduct; it covers what you can check yourself.
The five questions, in order
- Exclusivity. Is each lead sent to one firm only, and for how long?
- Consent. Can the vendor give you the stored consent record for each lead you will call?
- Definitions. Does the agreement define lead, contact, qualified, booked and attended in plain words?
- Returns. Which leads can you send back, within how many days, and for what credit?
- Cost per outcome. What does the price look like per appointment held and per retained case, using your own numbers?
Exclusivity and how to check it
"Exclusive" means nothing until the agreement says what it covers. Three versions exist and they are different products: sent to one firm only; sent to one firm in your territory only; sent to you first and resold later. Ask which one you are buying and get it in the agreement, including how long the lead stays exclusive.
You can test it yourself without trusting anyone's dashboard:
- Ask for the consent text and the page URL the person saw, then read the consent text. If it names several companies, or no company, the lead was never exclusive to you.
- During your paid test, submit a few forms yourself using email addresses and phone numbers you control, one per test. Note which businesses contact those addresses over the following weeks. This only tells you what happened to your test records, and a clean result is one data point, not proof.
- Ask whether the lead is deleted from the vendor's system or sold again after your window, and write the answer into the agreement.
Consent and the TCPA: what the rule says and who carries the risk
Most resolution leads get a phone call or a text from your intake team. That is where federal telemarketing law applies, and it applies to you as the caller, not only to the vendor.
The statute bars making a call "using any automatic telephone dialing system or an artificial or prerecorded voice" to a cellular number unless the call is "made with the prior express consent of the called party." The FCC's rule for telemarketing calls using autodialers or artificial or prerecorded voices requires "prior express written consent." That consent is defined as a written agreement "bearing the signature of the person called" that "clearly authorizes the seller" to deliver those calls to a specific number. The agreement must disclose that the person "is not required to sign the agreement" as "a condition of purchasing any property, goods, or services." An electronic signature counts where it is valid under federal law or state contract law.
The rule defines the seller as the entity on whose behalf the call or message is initiated. If your team makes the call, you are very likely the seller, and a consent record that never names you is a poor record to rely on when someone complains. The statute's private right of action lets a recipient recover "$500 in damages for each such violation," and a court may raise that to as much as three times the amount if it finds a willful or knowing violation. Calling hours are also written into the rule: no telephone solicitation to a residential subscriber "before the hour of 8 a.m. or after 9 p.m." local time at the person's location. Many firms set a tighter window of their own.
Many vendor pages mention a "one-to-one consent" requirement, meaning a single named seller per consent. On 12 November 2026 we read 47 CFR 64.1200 as published on Cornell's Legal Information Institute. Its definition of prior express written consent contains no single-seller language. The same page links an amendment published 26 October 2026 (91 FR 67219) whose text we could not read, so this guide cannot say whether it changes the consent rules. Check the current text on ecfr.gov, and ask counsel, before you rely on this section.
Records to ask for on every lead
- The exact consent text the person saw, with its version.
- The date and time, the page URL and the IP address recorded when the box was checked.
- The phone number and name as entered, matching the lead you received.
- The seller or sellers named in the consent text.
- How long the vendor keeps all of this, and a promise to hand it over within a fixed number of days if a complaint arrives.
A separate point for Enrolled Agents: Circular 230 section 10.30(d) says a practitioner may not "assist, or accept assistance from, any person or entity who, to the knowledge of the practitioner, obtains clients" in a way that section forbids. Section 10.30(a)(1) covers false, misleading or deceptive statements in communications about IRS matters. If a vendor's ads for your firm make claims you would not make yourself, the exposure is yours as well. The FTC's telemarketing rule adds a related risk: a person who provides "substantial assistance or support" to a seller who is violating the rule, while knowing it or consciously avoiding knowing, is itself violating the rule. Section 5 of the FTC Act reaches "unfair or deceptive acts or practices in or affecting commerce," which is the standard a vendor's ROI multiple or conversion promise would be measured against. Read your vendor's ads before they run under your name; the rules those ads must meet are in what a tax resolution firm can and cannot say in ads.
Definitions that belong in the contract
Every number a vendor shows you depends on these words. Write them into the agreement.
- Lead: one person, one phone number, one valid email, consent captured, submitted through a stated page. Say whether a repeat submission from the same person is a new lead.
- Contact: you reached a live person. Decide what counts: a connected call, a two-way text, a voicemail.
- Qualified: meets criteria you set before the test (how to set them is in screening tax resolution leads before they reach intake). Typical criteria are an owed balance above your floor, returns filed or fileable, a US resident, not already a client of yours, not a duplicate.
- Booked: a time on your calendar that the person confirmed. Say whether a booking that was rescheduled counts once or twice.
- Attended: the person was on the call or at the meeting. Say who records it.
Decide, too, who is the system of record. If the vendor counts and you count, you will disagree, and the contract should say whose count wins and that you can see the underlying records.
Where the balance floor goes
Vendors commonly advertise a minimum balance around $10,000 for a lead to count. That is a figure vendors state, not a rule, and the right floor for your firm depends on your fees, your staff and the cases you want. RevLab's own floor is $100,000, which is one firm's choice and not a benchmark. Set yours from your own fee and cost per case, and write it into the definition of qualified.
Pricing models and what each shifts onto you
| Model | You pay for | Risk that stays with you |
|---|---|---|
| Per lead | A form submission | Reachability, fit and consent quality |
| Per live transfer | A connected call | Fit and balance, and who recorded the consent |
| Per booked appointment | A confirmed calendar slot | No-shows and whether the person was ever qualified |
| Per attended appointment | A held meeting | Close rate, and a vendor will price this higher than a raw lead |
Moving down the table shifts more risk to the vendor and usually raises the price per unit. A lower price per lead can cost more per retained case if few are reachable or qualified, so compare on cost per outcome you care about.
Returns and refunds in practice
Get these in writing before the first invoice:
- Which defects can be returned: wrong or disconnected number, duplicate, outside your stated floor, no consent record, already your client.
- The window, counted from delivery, and the date by which you must file a return.
- The remedy: credit, replacement or cash back, and whether credits expire.
- Who decides a disputed return, and what evidence settles it.
- What happens to your data and the consent records if you stop buying.
If a vendor's terms say all sales are final, you carry all the risk of a bad lead, so keep the test small.
A 30-day test plan
Hypothetical example: you agree to buy 40 leads over 30 days. You count every lead the day it arrives, call within the same hour, and log each one in your own sheet as contacted, qualified, booked or attended. At the end of the month you total the money spent, divide by the number of attended appointments, and divide again by the number of retained cases. Those two figures, cost per attended appointment and cost per retained case, are what the test measures. The 40 only illustrates the method; it is not a prediction or a market benchmark.
- Before the first lead, write the definitions and the return terms into the agreement.
- Submit your own test records and request the consent record for each.
- Keep your own timestamped log. Do not accept the vendor's report as your only data.
- Return everything that qualifies for return inside the window.
- At day 30, decide by cost per attended appointment and per retained case, not per lead. Thirty days may be too short for cases that sign slowly, so note any appointments still open.
When buying leads is the wrong channel
If you cannot call a lead within the hour, if your intake team is already full, or if you have not set a floor, more leads will go uncalled or unscreened. Referrals, your own ads and a done-for-you service each carry different costs and risks. The comparison is in how tax resolution firms get clients: five sources compared.
Next step
If you are weighing whether to keep buying leads or run your own acquisition, you can book a strategy call with John on the RevLab homepage calendar.