Clayton M. “Mike” Carlson, CPA, Orinda, CA

Federal Practice

  • Peripheral Tax Products – Research Credit, Cost Segregation, Meals and Entertainment, IRC Sections 179D (energy) and 199 (domestic production)
  • Statistical Sampling Applied to Tax, Auditing and Accounting
  •  IRS Audit Defense
  • Software development using SAS, VBA, and SQL Server


Mike is associated with several service providers generating peripheral tax benefits for clients across the Western US in the areas of state and federal research credits, domestic production and increased meals, entertainment and depreciation deductions.

Specifically, he is working with small to mid-sized clients in the following lines of business: residential real estate rental; software development; medical device, gas turbine and clean room heating equipment manufacturing; ecological landscape, lighting and hotel design; plastics and pressure vessel fabrication, just to mention a few.

These affiliations are allowing Mike to use his extensive IRS and Big-4 experience and knowledge of federal and state taxes, statistical sampling and audit defense.


PwC, Tax Manager, San Jose, CA, where he managed and counselled staff in support of the same aforementioned peripheral tax products.  Mike also started PwC’s “CAS” (Computer Audit Specialist) practice in the service of clients under IRS examination where he was successful in negotiating scope reductions, easing tensions, reducing exam time and managing audit risk. 

Having been an IRS large case team member for over 27 years, Mike easily establishes himself, in the eyes of the client and the IRS, as a contributor to the progress of the exam.  Being the conduit for data requests and data responses, he is in a unique position, with his “auditor’s eye” to see the direction of the exam and provide warning of potential issues before they are fully developed, enabling the client to put the best face on a situation before the IRS can get too excited about it and waste everyone’s time diving too deeply into it.  This “early warning” provides unique opportunities for pre-audit risk assessments and management thereof.


Before joining PwC, Mike was a Revenue Agent, Computer Audit Specialist and Statistical Sampling Coordinator for a total of 32+ years at the IRS.  While in these roles, he served as a resource for examinations of the research credit – conducting interviews and evaluating research effort.  Because of his comfort with quantitative methods, he was sought out to appraise those methods employed by taxpayers and/or their representatives for purposes of cost segregation/repairs and meals and entertainment studies, IRC section 179D and 199 determinations.


Peripheral Tax Projects and Statistical Sampling Consultant, January, 2012 – present.

PricewaterhouseCoopers :  Tax Manager, January, 2008 - January, 2012.

Statistical Sampling Consultant – Research Credit, May 2007 - January, 2008

Internal Revenue Service: Revenue Agent, Computer Audit Specialist, Statistical Sampling Coordinator, December 1974 - May 2007


  • Federal Tax auditor of corporations, partnerships, sole-proprietorships and individuals.
  • Systems analysis, design and programming necessary to provide accounting data in a form useful to a tax audit team.
  • Federal Tax Law Instructor (IRS and SF City College).


  • CalCPA


  • BS, Accounting, California State University, Hayward, CA.
  • CPA - California


  • Journal of Taxation - October, 2011 - Shop Talk Column - "New Revenue Procedure on Statistical Sampling"
  • Journal of Taxation - August, 2010 - Shop Talk Column - "The Service's Field Directive on Sampling"
  • Tax Notes Today - Nov. 1, 1988 - "Silicon Valley Grapples with R&D Credit Questions"
  • San Francisco Examiner - Aug. 18, 1982 - "Federal Beat: Bay Area"
  • H-P Solutions Books - Tax Applications for H-P Programmable Calculators 1978-80.


  • SAS Programming
  • “R” Statistical Package Scripting
  • Visual Basic for Applications (“VBA”) (MS Access)
  • SQL Server
  • Data conversions
  • MS Office


IRS Special Act Award