The IRS selected your tax return for examination. Now every deduction, every income source, and every number you reported faces scrutiny. Our IRS audit attorneys step between you and the IRS, handle all communication, and build the strongest possible defense for your case.
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An IRS audit letter means the government wants proof. Proof of your income. Proof of your deductions. Proof that every number on your return is accurate.
IRS audit adjustments average $12,000 for individual returns. Accuracy-related penalties add 20% to any additional tax owed. Fraud penalties reach 75%. And if the IRS suspects willful underreporting, criminal prosecution becomes possible.
You have rights during an audit. The right to representation. The right to appeal unfavorable findings. The right to know exactly what the IRS is examining and why. Our tax audit attorneys make sure the IRS respects every one of them.
When you hire Silver Tax Group for audit representation, we take over all communication with the IRS. You never have to speak with a revenue agent, answer their questions directly, or attend audit meetings alone.
IRS audit defense is professional legal representation during an IRS examination of your tax return. Your audit defense attorney reviews the IRS notice, gathers supporting documents, communicates with revenue agents, and builds a strategy to reduce additional taxes, penalties, and interest.
The IRS conducts roughly 580,000 audits each year. Some are simple mail audits requesting a single document. Others are comprehensive field audits where agents spend days examining your financial records. Audit defense covers every type of examination, from the initial notice through final resolution or appeal.
IRS audits target individuals, businesses, and specific tax situations that raise red flags. If you received an audit notice or expect IRS scrutiny, we can help. Our audit defense attorneys represent the following clients:
The IRS audits individual tax returns for many reasons. High income, large deductions compared to income, unreported 1099 income, and math errors all trigger examinations. Whether your audit is random or targeted, we review your return, identify weak points, and prepare documents that support your filing position.
Self-employment income faces higher audit rates than W-2 wages. The IRS looks closely at Schedule C filers for unreported income, inflated business deductions, and home office claims. We help self-employed clients support their business expenses, document income sources, and respond to IRS questions about how they run their business.
Business audits examine payroll records, inventory, cost of goods sold, and owner compensation. The IRS looks for unreported cash income, personal expenses claimed as business deductions, and worker misclassification. Our attorneys understand business tax issues and defend companies facing IRS examination.
Taxpayers earning over $400,000 face audit rates three to five times higher than average filers. The IRS assigns specialized examiners to high-income audits. Complex returns with investments, rental properties, K-1 income, and itemized deductions require experienced representation to defend every line item.
If the IRS audited you before and found problems, they may audit later years too. Repeat audits often examine the same issues that triggered prior adjustments. We review your audit history, identify patterns, and build stronger documentation to prevent the same problems from happening again.
CP75, CP2000, Letter 566, Letter 525, Letter 2205. These notices all mean the IRS wants information. Some request a single document by mail. Others schedule in-person examinations. No matter which letter you received, responding correctly from the start shapes the entire audit outcome.
A correspondence audit is the most common IRS examination. The IRS sends a letter asking for documents or explanations about items on your return, and everything happens through the mail. These audits usually start because of missing W-2s or 1099s, charitable donations, or earned income tax credit claims.
If you respond the wrong way, the IRS can expand the audit or make automatic adjustments against you. We review the request, gather the right documents, write a response that addresses each issue, and submit everything before your deadline.
An office audit requires you to show up at an IRS office with your records. The IRS schedules these when they need to review multiple items or ask questions face-to-face. These audits usually focus on income verification, itemized deductions, or Schedule C business expenses.
You can send a representative instead of going yourself. Our attorneys appear for you, present your documents, answer the examiner’s questions, and keep you from saying something that could hurt your case.
Field audits are the most comprehensive IRS examinations. A revenue agent visits your home, business, or accountant’s office to review your books and records in person. These audits typically target business returns, high-income individuals, and complex situations involving multiple entities.
The examiner may request years of bank statements, accounting records, contracts, and supporting documents. Our attorneys manage the entire process, control what the IRS receives, and keep the examination within its authorized scope.
If you disagree with the audit findings, you can appeal before the IRS assesses additional tax. The Office of Appeals is independent from the examination division, and appeals officers can reduce proposed adjustments if your position has legal merit.
We prepare written protests explaining why the examiner’s findings are wrong, present your case to the appeals officer, and negotiate settlements that reduce what you owe. About 80% of cases that reach Appeals result in some reduction.
When Appeals fails to resolve your case, Tax Court is your next option. You have 90 days from receiving a Notice of Deficiency to file a petition. Miss this deadline and the IRS can assess the tax without further review.Filing a petition preserves your right to dispute the findings before paying.
Many cases settle after filing but before trial. Our attorneys prepare and file Tax Court petitions, represent you in settlement negotiations, and litigate cases that go to trial.
If you missed the deadline to respond to an audit or disagree with a closed examination, audit reconsideration may reopen your case. The IRS accepts these requests when you have new information that wasn’t available during the original audit or when procedural errors occurred.
We evaluate whether your case qualifies, gather the necessary evidence, and submit Form 12661 with documentation supporting your position.
Some audits reveal issues that could trigger a criminal investigation. Unreported income, false deductions, and fraudulent claims can result in referral to IRS Criminal Investigation. Warning signs include repeated questions about intent, requests for testimony under oath, and special agents getting involved.
Attorney-client privilege becomes critical when criminal exposure exists. Unlike CPAs, we cannot be forced to disclose what you tell us. If your audit shows signs of criminal referral, we adjust our defense strategy immediately to protect your rights.
IRS audit adjustments often trigger state tax audits. Most states receive federal audit information and assess corresponding state tax increases. Some states also conduct independent audits of income, sales tax, or employment tax.
We represent clients in state and federal audits together. Coordinating both defenses prevents inconsistent positions and keeps one resolution from creating problems with the other.
Every day you wait gives the IRS more time to build their case. Deadlines pass. Penalties accrue. One wrong answer can expand into a full financial review.
Our IRS audit attorneys have defended hundreds of taxpayers against IRS examinations. We know what revenue agents look for, how they think, and what documentation closes cases quickly. Put our experience between you and the IRS.
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Your information is 100% confidential and protected by attorney-client privilege.
Silver Tax Group provides full-service audit defense for individuals and businesses facing IRS examination. Our tax attorneys handle every stage of the audit process, from initial response through final resolution or appeal.
When an IRS audit concludes, you have several options depending on the findings.
If the IRS examination reveals accurate adjustments and you agree, you can sign the examination report and close the audit. Signing means you accept the additional tax, penalties, and interest.
This stops additional penalties and interest from adding up. You can pay the balance in full or request an installment agreement if you can’t pay immediately. Our attorneys review all proposed adjustments before recommending agreement to make sure the IRS calculations are correct.
Disagreeing with audit findings does not mean you must pay. You have 30 days from receiving the examination report to request an Appeals conference. The Office of Appeals operates independently and has authority to settle cases.
Appeals officers evaluate how a court might rule if the case went to trial. Strong documentation and legal arguments can result in significant reductions. About 80% of appealed cases result in some change to the proposed adjustments.
If Appeals cannot resolve your case or you receive a Notice of Deficiency (90-day letter), Tax Court is your next option. Filing a petition within 90 days preserves your right to dispute the tax before paying.
Tax Court lets you challenge IRS determinations before an independent judge. Many cases settle after filing but before trial. For disputes under $50,000 per tax year, small tax case procedures simplify the process. Our attorneys handle Tax Court petitions and represent clients through settlement or trial.
If you miss the 90-day Tax Court deadline, you can still dispute the audit by paying the assessed tax and filing a refund claim. After the IRS denies your claim (or six months pass), you can sue for a refund in U.S. District Court or the Court of Federal Claims.
This path requires paying first, which creates financial strain for many taxpayers. We help clients evaluate whether this option makes sense compared to other choices.
The IRS uses specific letters and forms throughout the audit process. Understanding what each notice means helps you respond correctly and protect your rights. Our attorneys handle all of these IRS audit documents on your behalf.
| Notice/Form | When You Receive It | What It Means |
|---|---|---|
CP75 NoticeView CP75 Information | After filing a return claiming refundable credits | The IRS is examining your Earned Income Tax Credit, Child Tax Credit, or other refundable credits and needs documentation to verify your eligibility. |
CP2000 NoticeView CP2000 Information | When reported income does not match IRS records | The IRS received W-2s, 1099s, or other information returns that do not match what you reported. This is a proposed adjustment, not a bill. |
Letter 566View Audit Information | When selected for correspondence audit | The IRS is examining specific items on your return and requests documentation by mail. This letter lists exactly what the IRS wants to review. |
Letter 525View Audit Information | When selected for office or field audit | The IRS is scheduling an in-person examination. This letter includes the date, time, location, and list of records you must bring or provide. |
Letter 2205View Audit Information | When business return selected for audit | The IRS is examining your business tax return. This notice identifies the tax periods under review and schedules an initial appointment. |
Letter 3219 (90-Day Letter)View Letter 3219 Information | After audit concludes with proposed changes you did not accept | This is a Notice of Deficiency. You have 90 days to file a Tax Court petition or the IRS will assess the proposed tax. This deadline cannot be extended. |
Form 2848Download Form 2848 PDF | When authorizing representation | Power of Attorney form that allows your tax attorney to communicate with the IRS, receive notices, and act on your behalf during the audit. |
Form 12661Download Form 12661 PDF | When requesting audit reconsideration | Disputed Issue Verification form used to request the IRS reopen a closed audit when you have new information or believe errors occurred. |
Facing an IRS audit requires more than general tax knowledge. You need attorneys who understand IRS examination procedures, know how revenue agents operate, and have experience defending taxpayers in everything from simple correspondence reviews to complex field examinations.
Yes. A tax attorney provides professional representation, handles all IRS communication, and protects your rights throughout the examination.
You can represent yourself, but one wrong answer can expand the examination or trigger additional scrutiny. Taxpayers who hire representation typically get better outcomes than those who handle audits alone. Attorneys also provide attorney-client privilege, which CPAs and enrolled agents cannot offer.
If your audit involves complex issues, large potential adjustments, or any concern about criminal exposure, professional representation is worth it. Contact us for a free case review to discuss your situation.
The IRS generally has three years from the date you filed your return or the return due date, whichever is later.
This three-year window extends to six years if you underreported income by more than 25%. There is no time limit for auditing fraudulent returns or returns that were never filed. The IRS can also extend this period if you sign a consent form agreeing to additional time.
Knowing which years the IRS can examine helps you prepare the right documents. Our attorneys review statute of limitations issues as part of every audit defense.
Common triggers include unreported income, high deductions compared to income, math errors, refundable credit claims, and random selection.
The IRS compares your return to statistical norms using a computer scoring system. Returns with high scores get flagged for examination. Specific triggers include large charitable donations, business losses reported multiple years in a row, home office deductions, and cash-heavy businesses. High earners face audit rates three to five times higher than average filers.
No matter why the IRS selected your return, proper representation helps you respond correctly from the start. We analyze your audit notice to understand exactly what triggered the examination.
Audit timelines range from 3-6 months for correspondence audits to 12 months or longer for complex field examinations.
The length depends on audit type, complexity of issues, how quickly you provide documents, and IRS examiner workload. Correspondence audits resolve fastest when you submit complete documents with your initial response. Office and field audits involve multiple rounds of document requests and meetings. Appeals add 6-12 months if you dispute the findings.
We work to resolve audits as quickly as possible while protecting your interests. Our attorneys manage deadlines, respond promptly to IRS requests, and keep your case moving toward resolution.
Yes. You can appeal to the IRS Office of Appeals within 30 days of receiving the examination report, or to Tax Court within 90 days of a Notice of Deficiency.
The Appeals process is free and does not require paying the proposed tax first. Appeals officers operate independently from examiners and have authority to settle cases. About 80% of cases that reach Appeals result in some reduction. Tax Court provides an independent judicial review if Appeals fails.
Disagreeing with audit findings does not mean you must pay. We help clients evaluate whether Appeals or Tax Court offers the best path forward based on the strength of their case.
Document requirements depend on what the IRS is examining but typically include bank statements, receipts, invoices, canceled checks, contracts, and accounting records.
Your audit notice specifies which items the IRS wants to review. For income audits, you need records proving all reported sources. For deduction audits, you need receipts and proof of payment. Business audits require books and records, bank statements, payroll documents, and supporting schedules. Missing records do not automatically mean disallowed deductions if you can prove expenses through other evidence.
We help clients organize documents and identify alternative proof when original records are unavailable.
Yes. Audits can result in criminal referral to IRS Criminal Investigation if the examiner finds evidence of willful tax evasion, fraud, or intentional underreporting.
Most audits are civil matters that result in additional tax, penalties, and interest. Criminal referrals happen in a small percentage of cases involving false documents, fictitious deductions, or deliberate concealment of income. Warning signs include repeated questions about intent, requests for sworn statements, and special agents getting involved instead of revenue agents.
Attorney-client privilege becomes critical if criminal exposure exists. Unlike CPAs, we cannot be forced to disclose what you tell us. If your audit shows any signs of criminal referral, contact us immediately.
The IRS has trained examiners, detailed procedures, and years of experience conducting audits. You deserve the same level of preparation on your side.
Here at Silver Tax Group, we’ve defended hundreds of taxpayers against IRS audits. We handle correspondence audits, office audits, field examinations, and Appeals cases. Our attorneys know what documentation closes cases, what arguments reduce adjustments, and what strategies protect your rights.
Your audit will not go away on its own. The sooner you get representation, the stronger your defense becomes.
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