IRS AUDIT DEFENSE
An audit is a record-building exercise. Everything that follows it — Appeals, Tax Court, penalties — is decided on the record the examination produces, and that record is largely built by the taxpayer’s own responses. This is the stage at which representation changes outcomes most and costs least.
An audit is decided by the record you hand over.
Every answer becomes evidence at Appeals and in court. Bring counsel in before the file is built, not after.
Scheduling does not create an attorney-client relationship. No such relationship exists until the firm has run a conflicts check and both sides have signed a written engagement agreement.
WHAT THE FIRM HANDLES
Every examination type
correspondence, office, and field, individual and business.
Information document requests
what is responsive, what is not, what is privileged, and what a production quietly concedes.
Privilege review before production
including Kovel arrangements where accounting analysis needs to sit inside the privilege.
Direct engagement with the agent
so the taxpayer is not the one answering questions under examination.
Method and substantiation
the two issues that decide most examinations, and the two most often conceded by accident.
Penalty exposure
assessed at the outset, not after the adjustment has already landed.
REAL ESTATE AND PARTNERSHIP EXAMINATIONS
Real estate is the firm’s core asset class, and the issues that arise on examination are the same ones the firm addresses in planning: passive activity classification under section 469, partnership allocations under section 704(b), basis under sections 704(d) and 752, depreciation method and recovery period, like-kind exchange treatment under section 1031, and self-employment tax exposure for limited partners and LLC members. Familiarity with these rules from the planning side translates directly into a faster and better-documented defense.
PRIVILEGE
Communications with an attorney are privileged. The section 7525 practitioner privilege available to accountants is narrower — it fails in criminal matters and in state proceedings, and does not extend to return preparation. Where accounting analysis is needed inside the privilege, the firm engages it under a Kovel arrangement so that the work is performed for the law firm rather than alongside it.
The detailed procedure is set out in The Exam Station.
Everything that follows an audit is decided on the record the audit produced.
HOW AN ENGAGEMENT BEGINS
Book a free consultation
Thirty minutes, no charge. Bring the notice — we read it together on that call.
The deadline is identified
Which notice it is, what it asserts, and which forums are still open behind it.
Conflicts check and written engagement
Scope and fee agreed in writing before any work begins.
HOW A CONTROVERSY RESOLVES
The firm takes over
Correspondence with the Service runs through the firm. You stop answering.
The position is built and pressed
Records, authority, and the argument — pressed at the earliest stage that will take it, because that is the cheapest place to win.
Resolution
Closed at examination, settled at Appeals on the hazards, or tried. The firm does not hand the file to anyone to reach the last of those.
An examination is easier to defend early than to unwind late. Contact the firm through the contact page or call (561) 529-5873. Representative engagements are described on the Experience page.