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.