Managing Complex IRS Audits of Large- and Medium-Sized Business Taxpayers

Navigating Examination Processes, IRS Summonses, Section 982 Foreign-Based Documentation, "Unagreed" Audits

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

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Conducted on Wednesday, February 18, 2015

Recorded event now available

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Course Materials

This course will provide guidance and best practices for responding to IRS audits of large- and medium-sized business taxpayers, including detailing IRS examination techniques, how to respond to and defend summons, navigating IRC Section 982 foreign-based documentation, and handling “unagreed” audits (appeals and fast-track settlement agreements).


Receiving an Information Document Request (IDR) from the Internal Revenue Service is stress-inducing, time-consuming and potentially costly. These requests generally signal the beginning of an audit or examination of a tax return. In cases where the IRS proceeds beyond a simple IDR to a full audit, the process becomes more complex. This can result in not only added expense in responding to the requests, but also significant legal and business implications that can produce unwanted future results if the taxpayer does not effectively respond.

The IRS has broad authority to carry out information requests and return examinations, but there are also significant limits on those powers that protect taxpayers undergoing an audit of a tax filing. Gaining a detailed understanding of the examination process, from the inception of an IDR through the more exhaustive audit and summons stages, will significantly benefit tax advisors to large- and medium-sized businesses in responding to IRS information requests. 

By knowing the audit process and the taxpayer protections built into the IRS directives for conducting audits, tax counsel and advisors can avoid mistakes that result in additional tax and sanctions.

Listen as our authoritative panel provides a thorough review of the IRS audit process, and discusses best practices for advisors to large- and medium-sized businesses for handling IRS information requests by outlining the taxpayer’s responsibilities and rights in an examination.



I. Overview of IRS Request for Information Processes

II. “Unagreed Audits” and IRS changes to taxpayer’s account

III. Taxpayer’s appeal rights and options

IV. Litigation options and strategies 


The panel will address these and other key issues:

  • What are the IRS’ powers in the various types of information requests at different stages of the audit/examination process?
  • What defenses may a taxpayer assert in response to an IRS summons?
  • What are the processes for the IRS to request foreign-based documentation?
  • What are the taxpayer’s options to challenge an IRS audit finding?


Jamie E. Brown
Jamie E. Brown

Kilpatrick Townsend & Stockton

Mr. Brown advises on tax-related matters, with a focus on federal tax controversies and litigation. Prior to...  |  Read More

Antoinette L. Ellison
Antoinette L. Ellison

Kilpatrick Townsend & Stockton

Ms. Ellison focuses her practice on the resolution of federal and state tax-controversies on behalf of individual and...  |  Read More

Susan S. Hu
Susan S. Hu

Kilpatrick Townsend & Stockton

Ms. Hu focuses her practice on tax controversy and litigation with a particular focus on corporate income tax,...  |  Read More

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Strafford will process CLE credit for one person on each recording. CPE credit is not available on recordings. All formats include course handouts.

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