Corporate Counsel Review
This article summarizes the statutory, regulatory and administrative rules and procedures that apply to IRS civil tax examinations and Appeals proceedings, including alternative dispute resolution procedures. The focus of this paper is on field examinations, rather than service center examinations, correspondence examinations, or office examinations. In addition, it attempts to answer some of the basic questions that taxpayers often ask their advisors and representatives when they are the subject of an IRS civil tax examination:
- Why was I selected by the IRS for audit?
- How long will this audit take?
- Why do the agents want all this information, documents, data, etc.?
- Do I have to give the agents all the information, documents, data, etc. they have requested?
- What can the IRS do if I don't cooperate in the audit?
- Can I recover from the IRS the fees and expenses I incur in the audit an din the Appeals proceeding?
- Should I ask for an Appeals conference?
Corporate Counsel Section of the State Bar of Texas
Emily A. Parker & Robert D. Probasco,
Surviving IRS Examinations and Appeals,
Corp. Couns. Rev.
Available at: https://scholarship.law.tamu.edu/facscholar/1235