Foresight Should be 20/20: Handling IRS Audits and Appeals with Later Tax Litigation in Minds

This presentation, designed for attorneys and accountants who do not specialize in tax controversy, provides an overview of a typical battle with the IRS, highlighting critical and obscure issues. It addresses strategic reasons for cooperating during audits, considerations before extending assessment-periods, special rules for third-party contacts, legal effects of various resolution methods, benefits of presenting “qualified offers,” avoiding inadvertent waivers of privileges, pros and cons of making tax “deposits,” how to shift the evidentiary burden to the IRS, which of three venues is best for bringing tax cases, why to file “protective” refund claims amid disputes, seeking reimbursement of legal fees from the IRS, and much more.