Articles Posted in LB&I

Inside the IRS Audit Playbook: How Revenue Agents Think, Investigate, and Decide
Kugelman Law

If you understand what an IRS Revenue Agent does on paper, you understand half of an examination. The other half — the half that determines outcomes — is how they think. The mental model an agent brings to a case shapes which issues get developed, which positions get pushed, which compromises get accepted, and ultimately…

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What Does an IRS Revenue Agent Do? An Inside Look at the IRS Audit Process
Kugelman Law

If you have received an IRS audit notice — or you are worried one might be coming — one of the first questions worth answering is who, exactly, will be examining your return. The answer matters more than most taxpayers realize. The IRS is not a single, undifferentiated organization. Examinations are conducted by specific employees…

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Why You Want a Former IRS Revenue Agent Attorney on Your Audit Defense Team
Kugelman Law

Most taxpayers who receive an IRS audit notice make the same first call: their CPA. A few call a tax attorney. Almost none think to ask a more useful question — does the firm I’m hiring have anyone on the team who has actually sat on the other side of the audit table? A former…

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