Often one's problems with the IRS start with an audit of previously filed income tax returns by a Revenue Agent from the IRS Examination Division. It is hard enough to pay taxes you anticipate and report. But it is often impossible to pay taxes that arise years later as the result of an audit, particularly when penalties and interest are added. The best way to deal with this problem is to avoid the "adjustments" to the returns in the first place. And effective representation during an IRS examination is an important factor in achieving a good outcome. We have represented clients in hundreds of IRS audits over the years, from simple one issue individual income tax examinations to multinational corporate cases involving complex issues and millions of dollars in taxes. Please contact us as soon as you find your returns are under examination, or if you have any reason to believe that they will be examined. We would be glad to help.

You can also wind up dealing with an audit like process when the IRS propses tax liabilities through its "substitute for return" or SFR procedures. This is done when the taxpayer fails to file returns when they are due, a subject discussed in more detail below.