IRS Audit Defense and Appeals — Pennsylvania Tax Attorney

Facing an IRS Audit in Pennsylvania?

Receiving an audit notice from the Internal Revenue Service (IRS) can be stressful for individuals and businesses alike. The IRS has broad authority to examine tax returns, and an audit can result in additional tax assessments, penalties, and interest. You do not have to handle the process alone. A Pennsylvania tax attorney can help you understand your rights, respond to the IRS, and, where appropriate, challenge audit findings through the appeals process.

What Is an IRS Audit?

An IRS audit is an examination of a taxpayer’s returns, financial records, deductions, and supporting documentation to verify compliance with federal tax law. Audits may be selected at random, prompted by items on a return, or connected to specific transactions.

If your return is selected, the IRS will notify you by mail. The notice will identify the type of audit — such as a correspondence audit conducted by mail or an office or field examination conducted in person — and the items under review, and it will typically request documents or information. This is often the point at which taxpayers choose to consult a tax attorney. After receiving a notice, it is important to gather the relevant records, receipts, and documentation that relate to the items being examined, and to respond by the stated deadlines.

The Examination Stage

During the examination stage, an IRS auditor reviews the return and related records. The auditor may request additional information, interview the taxpayer or the taxpayer’s authorized representative, and analyze financial documents.

A tax attorney can assist during an examination by:

• Communicating with the IRS on your behalf and responding to information requests
• Helping you organize records and documentation that support the positions taken on your return
• Advising you on your rights as a taxpayer, including the right to representation
• Working to address areas of concern as they arise during the examination

At the end of the examination, the IRS will issue its findings, which may include proposed adjustments to your tax liability.

If You Disagree: The IRS Appeals Process

Taxpayers have the right to disagree with an auditor’s proposed adjustments. If you receive a letter proposing changes (often called a “30-day letter”), you generally have 30 days to request a conference with the IRS Independent Office of Appeals, a body within the IRS that operates separately from the examination function. Depending on the amount in dispute, this may involve filing a formal written protest. Deadlines in this process matter, and a tax attorney can help you evaluate your options and submit a timely, well-supported appeal.

In an appeal, a tax attorney can help present your position based on the facts, applicable law, and relevant authorities, and can engage in discussions with the Appeals Officer aimed at resolving the dispute without litigation.

United States Tax Court

If the matter is not resolved through appeals, the IRS may issue a Notice of Deficiency (sometimes called a “90-day letter”). A taxpayer who receives a Notice of Deficiency generally has 90 days to file a petition with the United States Tax Court, where the dispute can be heard by a judge before the tax is paid. An attorney admitted to practice before the Tax Court can represent you in those proceedings and advocate for your position.

Attorney Advertising. This page is for general informational purposes only and does not constitute legal or tax advice. Reading this page or contacting the firm does not create an attorney-client relationship. Outcomes depend on the specific facts and circumstances of each matter, and prior results do not guarantee a similar outcome.