Overview: IRS Examination Process

Practice, CCH Incorporated, December 2014-January 2015

5 Pages Posted: 15 Aug 2015

See all articles by Charles P. Rettig

Charles P. Rettig

Hochman, Salkin, Rettig, Toscher & Perez, P.C.

Date Written: January 1, 2015

Abstract

Representation of clients involved in an audit or dispute with the IRS requires the exercise of considerable judgment, discretion, and caution. There are often unknown, potentially sensitive issues that might unexpectedly arise during the course of any audit. Throughout, the representative must balance their duties to their client with the representative’s ethical and legal obligations. Effective representation requires that the representative understand the entire administrative process and the inherent limitations involved at each level of the administrative process. Further, the representative must be able to acknowledge their own limitations.

It is generally advisable to attempt to resolve any civil tax dispute at the earliest opportunity. A lengthy audit may be costly from the perspective of the expenditure of time and effort involved, as well as the taxpayer’s degree of frustration with the normal administrative process. Further, a prolonged audit is more likely to uncover potentially sensitive issues that could generate increased tax deficiencies, penalties, or the possibility of criminal sanctions. The administrative process should not be abused merely because of the taxpayer’s desire to delay the determination and collection of any potential liability. Collection-related issues should be sorted out through an installment payment arrangement that would be negotiated through the normal collection process following conclusion of the audit process.

Keywords: IRS examination, IRS, IRS audit, Internal Revenue Service, tax dispute

Suggested Citation

Rettig, Charles P., Overview: IRS Examination Process (January 1, 2015). Practice, CCH Incorporated, December 2014-January 2015, Available at SSRN: https://ssrn.com/abstract=2643812

Charles P. Rettig (Contact Author)

Hochman, Salkin, Rettig, Toscher & Perez, P.C. ( email )

9150 Wilshire Blvd., Suite 300
Beverly Hills, CA 90212
United States

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