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IRS Audits: Responding to IDRs, Independent Office of Appeals, Extending the Statute, and Current IRS Initiatives

Note: CLE credit is not offered on this program

Recording of a 110-minute CPE webinar with Q&A

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Conducted on Tuesday, May 26, 2020

Recorded event now available

or call 1-800-926-7926

This course will provide tax advisers with insights on handling IRS audits from inception to resolution, including responding to IDRs (information document requests), extending the statute, working with newly titled Independent Office of Appeals, and litigating unresolved issues. The panel will review areas the IRS is targeting, how to cooperate without oversharing, and steps to take to lessen the chance of selection.

Description

All tax practitioners need to be up-to-date on the latest IRS tax initiatives and current IRS audit procedures. Before the audit takes place, advisers need to understand the different types of examinations, the current IRS audit process, and when returns are no longer subject to audit. The type of audit: correspondence, office, field or compliance affects the effort and ease of resolving the issue(s) raised.

Since most audits take place just before the statute runs, deciding whether to grant the IRS an extension of time is often a critical initial consideration. Throughout the process, there is a fine line between cooperating with the IRS and its voluminous information document requests (IDRs) and providing information that could be damaging.

Most practitioners are aware of the benefits of appeal after receiving a disagreeable Revenue Agent's Report. Here, a case may settle for less than the full amount assessed. The recently enacted Taxpayer First Act of 2019 ensures all taxpayers with legitimate claims have access to the IRS independent appeals process.

Certain taxpayers, those with AGI of $400,000 or less or business taxpayers with gross receipts of $5 million or less, can request access to their file before going to court. Filing an effective written protest can circumvent going to court, saving the taxpayer significant time and money. Then again, there are times when a 90-day letter and trip to tax court may be the best or only alternative.

Listen as our panel of experts explains the IRS examination process, how to handle appeals when court is a viable alternative, and steps taxpayers can take to circumvent or ease the audit process.

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Outline

  1. Types of IRS examinations
  2. Audit selection process
  3. Current IRS initiatives
  4. Responding: IDRs and correspondence
  5. Extending the statute
  6. Appeals
  7. Litigation
  8. Criminal investigations

Benefits

The panel will review these and other important issues:

  • The effect of the Taxpayer First Act on the IRS audit process
  • How to respond to disagreeable Revenue Agent Reports
  • Current areas IRS is targeting for examinations
  • Considerations when responding to IDRs
  • Negotiating with the Independent Office of Appeals

Faculty

Stein, Michel
Michel R. Stein

Principal
Hochman Salkin Toscher Perez

Mr. Stein specializes in tax controversies, as well as tax planning for individuals, businesses and corporations. For...  |  Read More

Stigile, Cory
Cory Stigile

Principal
Hochman Salkin Toscher Perez

Mr. Stigile specializes in tax controversies as well as tax, business, and international tax. His representation...  |  Read More

Toscher, Steven
Steven (Steve) Toscher

Managing Principal
Hochman Salkin Toscher Perez

Mr. Toscher has been representing clients for more than 35 years before the Internal Revenue Service, the Tax Divisions...  |  Read More

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