Anatomy of a Civil Tax Controversy

There is a certain rhythm to the audit process, and it's a very scary beat. In this presentation, I'll discuss the steps that most examinations begin and end with. We'll discuss eggshell audits, those audits where unbeknownst to the IRS at the start of the examination, the taxpayer has major criminal problems and what you can do to help shepherd your client through the pending storm.

We'll also discuss the attorney-client privilege in the tax realm as well as the necessity to retain a Kovel accountant when there are underlying criminal tax issues that are lurking. Finally, we'll take a short digression into IRS Appeals. Curriculum / Topics covered:1.

What are the primary steps involved in the IRS audit process, and how can taxpayers prepare for each stage. 2. In what ways does the Appeals process maintain its independence from the IRS compliance function, and why is this independence critical.

3. How do the ex parte communications rules impact the interaction between Appeals and compliance during a tax controversy. 4.