Internal Revenue Service (IRS) examinations or audits, including but not limited to:

  • Civil examinations or audits:
    • Correspondence audit;
    • Office audits;
    • Field examinations or audits; and
    • Prohibition on second audits;
  • Criminal examinations or audits:
    • Criminal investigation of IRS, as well as Department of Justice; and
    • Searching through FOIA for references to CI or other “5th Amendment” matters;
  • Selection for audit:
    • Learning and understanding how the taxpayer was selected for audit, helps understand what you are fighting against, with such selections including:
      • Computer selection;
      • Related party audits;
      • Return disclosures;
      • Initiatives in areas of noncompliance;
      • Informants and information from agencies; and
      • Audits to develop compliance initiatives;
    • IRS players in the audit process:
      • Revenue agent;
      • Other disciplines;
      • Industry experts;
      • Counsel;
      • National office players; and
      • Criminal investigation agent;
    • IRS initiation of the audit;
    • IRS information gathering process:
      • Informal requests;
      • Information document requests (IDRs); and
      • Third party contacts;
      • IRS administrative summons:
      • Section 7602 summons;
      • Powell standards;
      • Routine for summons;
      • Summons in criminal investigations;
      • Third party summons;
      • John doe summons (fishing expedition);
      • Designated summons; and
      • Litigation regarding summons;
    • Privileges:
      • Attorney-client;
      • Work-product;
      • Fifth Amendment;
      • Tax practitioner;
      • Doctor/patient;
      • Priest/penitent; and
      • Kovel engagement;
    • IRS methodology for determining additional tax liability:
      • Specific items;
      • Net worth method; and
      • Bank deposits and expenditures method;
    • Obtaining the revenue agent report (RAR);
    • Settling matters at examination level;
    • Requesting closing agreements.