Strategies for Defending and Protecting Clients During the Audit Process

This 29-page research report written for tax attorneys features key steps to take when defending a client in an audit. The audit process is covered in its entirety, from the red flags that trigger an audit to the circumstances that determine whether it is best to go to trial or settle. The report presents the consequences that may arise from an audit and the factors those consequences are based on. Leading tax attorneys discuss at what point during the audit process should the attorney become involved and how to work with the client to develop a strategy. Also presented in this report are methods for working with the Internal Revenue Service to achieve the best results and successfully defend a client.

Other topics include:

• the appeals process
• the Criminal Investigations Division
• the audit process timeline
• mass settlement initiatives
• ninety day letters
• tax court petitions
• working with nonprofits
• recordkeeping
• e-mail
• no-change letters
• the Internal Revenue Code
• the signs that a client will face trouble

This Executive Report is written by:

• Arthur M. Nathan, Partner, Haynes and Boone LLP - Gathering the Facts to Defend a Client in an Audit
• Gilbert Boyce, Partner, Kutak Rock LLP - Determining an Audit Strategy
• Michael D. Fernhoff, Partner, Chair, Los Angeles Tax Practice Group, Kaye Scholer LLP - Tax Audits and Litigation
• Michael I. Sanders, Partner, Head of Powell Goldstein's Tax Department, Powell Goldstein LLP - Protecting the Client in an Audit
• Schuyler Moore, Partner, Stroock & Stroock & Lavan LLP - Defending the Individual and the Client in an Audit
• Gregory G. Pavin, Partner, Winston & Strawn LLP - Preparing for an Audit
• Stuart M. Lewis, Shareholder, Buchanan Ingersoll & Rooney PC - Approaching an Audit
• Joel I. Krieger, Shareholder and Director, Wallace Saunders, Austin, Brown & Enochs, Chtd. - The Initial Meeting with an Executive Who is Being Audited: Determining a Defense Strategy

About Executive Reports:

Executive Reports offer focused, hard-hitting advice from the leaders of some of America's top companies, packaged in a concise, readable format. Each research report provides readers with 3 to 5 strategies that will have a direct financial impact on their business. While not meant as a comprehensive guide, each report includes quick-hit items that can immediately impact specific business strategies. Executive authors drill down to the central issues surrounding each topic area and dispense expert advice in concise, direct language. Executive Reports feature leading professionals selected by the Aspatore Editorial Board based on their experience, research, and standing within the professional community.