IRS Audits & Appeals

When people call about this

What this usually looks like

• A letter is asking you to substantiate specific deductions
• An office or field examination has been scheduled
• The examiner’s proposed adjustment does not match your records
• You disagree with the result and the thirty-day letter is running

How it actually works

The part that decides the outcome

Examinations come in three shapes. Correspondence audits arrive by mail and question a narrow item. Office audits bring you in. Field examinations come to the business, look wider, and last longer. What they share is that the outcome turns on substantiation — on whether the record supports the position taken on the return.

When the examination closes badly, it is not the end. Administrative Appeals is a separate function with a different mandate: it weighs the hazards of litigation rather than defending the examiner’s conclusion. Cases that are unwinnable across the table are frequently resolvable one level up, and the deadline for getting there is short.

Where a return was never filed, the first contact often looks like an examination and is really the beginning of a collection file. Recognizing which one you are in changes what you should say.

The engagement

How we work a case like this

1. Read the file first

What is actually being questioned, for which periods, and what the examiner already holds.

2. Substantiate

Assemble and present the record — organized, complete, and limited to what was asked.

3. Appeal when the answer is wrong

Preserve the deadline and take hazards of litigation to a function that weighs them.

Related matters

These rarely arrive on their own

Tax problems overlap. The pages below are the ones that most often belong in the same file as this one.

This page is general information, not advice for a specific situation. Available procedures depend on the actual record and on current law, which changes. Confirm before acting, or ask this office to review your own facts.