Client Representation Before the IRS Exam Division

Author: Samantha Gozlan

Per the IRS Education Provider Standards this course must be COMPLETED by 12/31/2027 to receive credits. NOTE: Go to My Professional Profile in your CCH CPELink account settings to ensure your name, and PTIN number; matches your PTIN card

Traditionally, the CPA or enrolled agent has enjoyed a comfort level in representing clients in the IRS examination division. However, the Service’s expanding use of criminal parallel investigations and the new complexities built into the new BBA procedures and the many and varying voluntary disclosure programs and settlement initiatives have created a system wherein legal representation is a necessity. Learn the ways in which an attorney and the accountant can work as a team at the examination stage to protect the clients’ rights and interests and to enhance the ability to secure favorable case resolution at the examination level.

Publication Date: July 2024

Topics Covered

• Organizational Makeup
• Lifecycle of an Examination
• Practice Points
• Hot Issues in IRS Compliance

Learning Objectives

• Identify and navigate IRS parallel civil and criminal investigations in sensitive or high-risk audits
• Identify best practices and strategies in responding to IRS document requests, statute of limitations extension requests, and other IRS audit techniques
• Recognize how to strategically assist the client in evaluating and utilizing the various and constantly evolving IRS voluntary disclosure programs
• Identify the new BBA procedures in place for large partnership and pass-through entity examinations
• Identify the individual involved in a taxpayer’s audit that deals with a specific Code Section issue

Level
Intermediate

Instructional Method
Self-Study

NASBA Field of Study
Taxes (2 hours)

Program Prerequisites
Some basic knowledge of IRS process

Advance Preparation
None