Receiving an IRS audit notice can be stressful for individuals and businesses alike. In many cases, a tax audit is triggered by mismatched information reporting or statistical selection through the IRS audit system. Often a narrow first information document request (IDR) and correspondence audit quickly expands to a full field audit. IRS tax examinations can include income tax disputes, payroll tax matters, international transactions, and complex business structures.
Effective audit representation often requires both technical tax knowledge and strategic engagement with the IRS. An experienced tax audit defense attorney can help. Tax counsel can assess risk, develop tax technical positions, and negotiate with the IRS to limit the scope and impact of tax examinations.
Common IRS Audit Issues
IRS examinations can involve:
- Business expense deductions or losses
- Income reporting discrepancies
- Income or expense character or timing differences
- Payroll tax compliance
- Related-party transactions
- R&D credit claims
- Partnership and pass-through entity reporting
IRS Audit Defense Process & Strategy
- Consider engaging an experienced IRS audit defense lawyer as soon as possible.
- Consider Streamlined Filing Compliance or Voluntary Disclosure (if eligible).
- Don’t ignore IRS correspondence, be proactive, meet deadlines or obtain extensions.
- Carefully evaluate issues to assess risk and develop audit management strategy.
- Develop tax technical and factual support for contested positions and limit audit scope / expansion.
- Prepare responses and supporting documentation and respond to IDRs.
- Obtain audit closure confirmation, negotiate (settlement, repayment plan, penalty abatement, etc.), or prepare for potential protest and IRS Appeals review.
Early involvement of tax audit counsel can often significantly improve the outcome of the examination.
Contact an experienced IRS audit defense attorney
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