Client Representation Before the IRS Exam Division

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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.

Topics Covered

• Tax Controversy
• IRS Representation
• IRS Examinations
• Parallel Investigations
• Voluntary Disclosure Programs
• Settlement Initiatives
• Accountants & Attorneys work relationship

Learning Objectives

• Achieve a comfort level in the context of an IRS income tax examination
• Anticipate and navigate IRS parallel civil and criminal investigations in sensitive or high-risk audits
• Utilize best practices and strategies in responding to IRS document requests, statute of limitations extension requests, and other IRS audit techniques
• Strategically assist the client in evaluating and utilizing the various and constantly evolving IRS voluntary disclosure programs
• Navigate the new BBA procedures in place for large partnership and pass-through entity examinations

Level
Intermediate

Instructional Method
Group: Internet-based

NASBA Field of Study
Taxes (2 hours)

Program Prerequisites
Some basic knowledge of IRS process

Advance Preparation
None