Skilled Legal Counsel Handling IRS Audits And Appeals

Receipt of an IRS Notice of Audit Examination

Nothing can be more terrifying than receiving a notice from an IRS revenue agent your tax return(s) have been selected for audit examination. Your initial response should not be to call the revenue agent and ask what they are looking for or to schedule the audit examination. Worse yet would be to advise the revenue agent that perhaps there are mistakes on the return but they were unintentional. Rather, your obligation now to you and your family is to retain a tax attorney experienced with handling the audit examination.

Submit to a Taxpayer Interview

Working with an attorney protects the information that you share under the attorney-client privilege. The information that you divulge to an employee working at a "tax mill," enrolled agent or even a CPA is not privileged communications and therefore can be transmitted to the tax authorities and used against you.

My experience in dealing with revenue agents means that you won't have to be interviewed. The interview process can be the most sensitive part of the audit investigation and my representation will ensure that you will not have to be interviewed.

Responding to the IRS Information Document Request

Nothing can be more terrifying that receiving an Information Document Request (IDR) with request for documents that you don't have; or worse yet, are afraid to provide. Knowing how to respond to this situation takes an experienced tax attorney. Do not have a representative who simply turns to you and says go ahead and provide the documents. If that happens you are not getting adequate counsel.

Explanation of Errors and Omissions

Handling an IRS audit, especially one where there are mistakes and/or omissions on the returns, requires a tremendous amount of skill and experience. Audit representation is more than showing up with the taxpayer and providing the requested documents to the IRS revenue agent. This is a serious matter and you need a customized plan based upon a careful evaluation of the facts and pertinent documents. Generally, allowing your CPA or tax return preparer this task is not in your best interest as his or her experience in audits is infrequent and no attorney-client privilege exists. Lastly, he or she may feel compelled to protect his or her work which leaves the client in a very difficult situation.

Personal Attention and Custom-Tailored IRS Audit Examination

At the Law Offices of Robert T. Leonard, we understand that IRS audits can have serious implications for you, your family and your company. Accordingly, we provide you with direct attention from an experienced lawyer who will give you sound advice and potent legal strategies that these matters require. At your first consultation, you will meet with attorney Rob Leonard, and you will continue to work with him directly until the conclusion of your IRS audit. You will never be passed off to a less experienced associate or non-lawyer advocate.

Did You Just Receive a Notice of Audit Examination? Contact Our Firm

Call us at 818-224-7935 or toll free at 888-408-9486, or contact us online, to arrange a confidential consultation with Mr. Leonard. Initial consultations are offered free of charge. From our Woodland Hills office, we serve clients in Los Angeles and the San Fernando Valley, as well as those across California and throughout the United States.

Hi, I'm Robert Leonard, I'm an attorney and CPA and I specialize in tax litigation and tax controversy matters. When a taxpayer receives an IRS notice of audit examination, there is usually a lot of anxiety and that is followed by numerous questions.

There are two important questions that a taxpayer should address. The first question is: do they need representation? That depends. If it’s a correspondence audit whereby they just mail in documents to the IRS, then they probably don’t need representation. However, if it’s an office audit, that is where they meet with the revenue agent at the IRS office or if its a field audit, where the revenue agent meets with them at their place of business or residence, then they do need representation for a number of reasons.

Here are just a few: a representative should be able to reduce the scope of the audit, meaning that the number of issues on the tax return or the years involved. The representative will know what documents to provide and not provide, and the taxpayer will not need to be interviewed by the revenue agent, so they won't be in a position to make matters worse. Second question: who should they hire? They should hire a tax attorney who specializes in audit representation. With a tax attorney their conversations will be protected because of the attorney-client privilege. They don't have that same privilege with their CPA, or an enrolled agent, or a tax return preparer. And it's critical to have that privilege. Further, they need an experienced tax attorney. This is a serious matter most likely causing sleepless nights and they need the best representation available.

As part of my representation I understand the importance of communicating with my clients. They want to know what the strategy is and they want updates. They want telephone calls returned promptly. I provide that service. I know how to listen carefully to my clients.

Contact me if you’ve received an IRS notice of audit examination, let's discuss your particular situation and the best way to resolve the problem.

I can be reached at (818) 587-3333. I look forward to your call.