The way you work with an IRS examiner can sometimes mean the difference between a no-change letter and a referral to the Criminal Investigations Unit. In this course, we walked you through best practices for guiding a client through an IRS examination, and common pitfalls to avoid, from the perspective of a tax litigation lawyer who has seen the results of examinations done right and very, very wrong.
- Adequately preparing a client for an IRS exam, including how to preserve documents and how to provide only what needs to be provided to the IRS.
- Justifying the value of being able to switch the burden of proof from the taxpayer to the IRS at trial, and how to preserve the right for your client to be able to do that by following certain steps during the examination.
- Identifying common mistakes in responding to document requests.
- Identifying common conflicts of interest between the representative and the client.
- Analyzing the ways to best position your client to avoid penalties.