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Responding to Adverse IRS Audit Assessments: Audit Reconsideration Requests, IRS Appeals, Settlement Strategies

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, January 17, 2023

Recorded event now available

This course will provide tax advisers and professionals with a discussion of IRS exam hotspots. It will outline practical strategies for responding to unfavorable IRS audit results, including requesting audit reconsiderations, navigating the IRS appeals process, and the litigation options available. The participants will learn how to adequately represent and negotiate with the IRS during the audit and through the reconsideration and appeal process.

Description

Few events are as stress-inducing and potentially costly for a taxpayer as an adverse tax audit finding. While some IRS adjustments are justified, often adverse results arise from insufficient documentation, failure to appropriately respond to an information document request (IDR), failure to file a required return or lack of understanding by the IRS of its own rules and regulations. The Internal Revenue Code provides many avenues for appeal and reconsideration, and tax advisers should know the various forums and procedures for challenging an audit determination.

Under certain circumstances, an audit reconsideration request can be an appropriate and effective means of resolving a dispute with the IRS. Audit reconsiderations involve requesting the IRS to evaluate prior audit results by a revenue agent. Audit reconsiderations generally require that a taxpayer have new evidence in the form of a new or corrected filing or additional documentation not previously submitted to the examining agent. An alternative approach to achieving a similar result is by filing an offer in compromise based on doubt as to liability or filing a request for a collection due process hearing.

The IRS appeals process can also provide a more beneficial and cost-effective way of resolving an adverse audit finding. Because appeals officers must consider the "hazards of litigation" when reviewing a taxpayer's appeal, taxpayers often have a greater chance of achieving a favorable settlement in an IRS appeal due to the appeals officer's mandate to consider the assessment's defensibility in court.

Listen as our authoritative panel reviews the IRS audit process and discusses best practices for advisers to determine the best course of action in responding to an adverse audit finding.

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Outline

  1. Responses to initial IRS examination contact
  2. Responding to IDRs, and requests for taxpayer interviews
  3. Statute of limitations issues during the audit process
  4. IRS appeals process: strategies and requirements
  5. Offers in compromise based upon doubt as to liability
  6. Audit reconsideration requests
  7. Contesting notices of deficiency: litigation alternatives
  8. Collection due process hearings

Benefits

The panel will discuss these and other vital questions:

  • How to respond to Information Document Request Form 4564
  • How to respond to IRS requests for taxpayer interviews
  • Strategies and requirements for audit reconsideration
  • Under what circumstances should a representative advise the taxpayer to extend the statute of limitations?
  • When is the IRS appeals process beneficial for taxpayers?
  • What belongs in an appeals protest?
  • When should a representative advise filing a petition with the U.S. Tax Court?

Faculty

Brager, Dennis N.
Dennis N. Brager, Esq.
Certified Tax Specialist
Brager Tax Law Group

Mr. Brager is a nationally known tax litigation attorney, representing clients in criminal and civil tax litigation and...  |  Read More

Frank, Cheryl
Cheryl R. Frank
Attorney
Brager Tax Law Group

Ms. Frank is a former Senior Tax Attorney in the Tax Litigation Division of the IRS Office of Chief Counsel in...  |  Read More