IRS Audits & Examinations
Bakersfield IRS Audit Attorney
An IRS audit can begin with a simple request for records and quickly develop into a much larger tax dispute. What you provide, how you respond, and what you say during the examination can significantly affect the outcome.
I am a Bakersfield tax controversy attorney representing individuals and businesses in IRS audits and examinations throughout Kern County and California. I deal directly with IRS revenue agents and examiners so my clients do not have to navigate the examination alone.
My job is not simply to forward documents to the IRS. It is to determine what the IRS is examining, understand the potential exposure, develop the factual and legal support for the return, and challenge proposed adjustments when the government gets it wrong.
If you have received an IRS audit notice or have already been contacted by a revenue agent, getting an attorney involved early can help keep the examination focused and protect your rights.
Received an IRS audit notice? Contact my Bakersfield office before responding to the IRS.
How I Handle an IRS Audit
I do not begin an audit by simply turning over everything the IRS asks for.
First, I want to understand the case.
I review the tax returns, the audit notice, IRS transcripts, the issues being examined, and the records available to support the return. I want to know what the revenue agent is looking for, why the IRS is asking for particular information, and whether there are issues that could cause the examination to expand.
From there, I develop a strategy for responding.
Whenever possible, I communicate directly with the revenue agent so my client does not have to. I review document requests before anything is produced, organize the evidence around the specific issues being examined, and provide the IRS with the information necessary to support our position without unnecessarily opening new areas of inquiry.
I also do not treat every IRS audit as a fight.
If an issue can be resolved efficiently with the right documents or explanation, that is usually the best result. But I do not assume that an IRS examiner's interpretation of the facts or tax law is correct simply because it comes from the government.
When I disagree with a proposed adjustment, I develop the record during the examination with the possibility of IRS Appeals or Tax Court already in mind.
That distinction is important.
An audit is not just about getting through the next document request. It is about protecting the taxpayer's position from the beginning of the examination through its ultimate resolution.
What Happens During an IRS Audit?
An IRS examination is a review of a tax return to determine whether income, deductions, expenses, credits, or other items were reported correctly.
Some audits focus on a single issue. Others expand into additional tax years, business entities, payroll taxes, penalties, bank deposits, or other areas of potential exposure.
IRS audits are generally conducted through:
Correspondence Audits
A correspondence audit is handled primarily through the mail and usually focuses on one or more specific items on a tax return.
The IRS may request documentation supporting deductions, business expenses, credits, income, filing status, or other reported items.
Although these audits may appear routine, an incomplete or poorly prepared response can result in deductions being disallowed and additional tax and penalties being assessed.
I prepare the response, organize the supporting evidence, address the legal issues, and communicate with the IRS on the taxpayer's behalf.
Office Audits
An office examination generally involves direct interaction with an IRS examiner and may include a broader review of the return and supporting documentation.
I can prepare the taxpayer for the examination, determine what records should be produced, respond to follow-up requests, and address disputed issues as they arise.
Field Audits
A field examination is generally the most comprehensive type of IRS audit.
A revenue agent may examine accounting records, bank deposits, gross receipts, expenses, payroll, related entities, shareholder or partner transactions, and multiple tax years.
For business owners and taxpayers with complex returns, these examinations require particular care.
Documents and statements made during the audit can affect the government's position later in the case. I therefore approach a field examination not merely as an accounting review, but as a potential tax controversy that may ultimately proceed to IRS Appeals or court.
IRS Audit Representation in Bakersfield and Kern County
Bakersfield and Kern County have a large number of closely held businesses, self-employed professionals, agricultural operations, oil and energy businesses, contractors, trucking and transportation companies, healthcare professionals, real estate businesses, and other taxpayers with returns that can involve substantial business income and deductions.
When one of those returns is selected for examination, the issues can extend well beyond producing receipts.
The IRS may examine:
- Gross receipts and bank deposits
- Business expenses and deductions
- Cost of goods sold
- Payroll and employment taxes
- Independent contractors
- Shareholder and partner transactions
- Officer compensation
- Depreciation and business assets
- Related entities and related-party transactions
- Personal expenses paid through a business
- Unreported or reconstructed income
- Penalties
I represent Bakersfield and Kern County taxpayers before the IRS in individual, business, and employment tax examinations.
Because IRS matters are federal, representation is not limited to Bakersfield. I can represent taxpayers in IRS examinations throughout California and before IRS personnel located outside Kern County.
What Does an IRS Audit Attorney Do?
Effective IRS audit representation is about managing the examination and developing the factual and legal record from the beginning.
Depending on the case, my representation may include:
- Reviewing the audit notice, tax returns, transcripts, and examination history
- Filing a Power of Attorney and communicating directly with the IRS
- Responding to Information Document Requests
- Reviewing records before they are provided to the IRS
- Preparing the taxpayer for an interview when one is necessary
- Organizing and presenting supporting documentation
- Researching disputed tax issues
- Addressing unnecessarily broad or irrelevant requests
- Challenging proposed penalties
- Reviewing Form 4549 and examination reports
- Preparing a protest to the IRS Independent Office of Appeals
- Preserving the taxpayer's right to challenge a deficiency in Tax Court
The objective is straightforward: resolve the examination at the earliest appropriate stage while protecting the taxpayer if the dispute must continue.
Do I Have to Speak With the IRS Revenue Agent?
Not necessarily.
Taxpayers have the right to retain an authorized representative in their dealings with the IRS. Once I am authorized to represent a client, I can generally communicate directly with the revenue agent and handle much of the examination through my office.
Whether the taxpayer should personally participate in an interview depends on the circumstances.
Before my client sits down with a revenue agent, I want to know what the agent is investigating, what information the IRS already possesses, what subjects are likely to be discussed, and whether the interview is necessary.
An IRS interview should not be treated as an informal conversation.
What If I Don't Have Every Receipt or Record?
Missing records do not necessarily mean the IRS automatically wins.
The appropriate response depends on what is being examined, what the law requires the taxpayer to establish, and what other evidence is available.
Depending on the issue, relevant evidence may include bank statements, canceled checks, invoices, contracts, accounting records, business records, third-party documentation, reconstructed records, and testimony.
The objective is to determine what actually needs to be proven and then develop the strongest available evidence to prove it.
Sending an examiner hundreds of pages of unorganized records without explaining what those records establish is usually not an effective audit strategy.
What If the IRS Proposes Additional Tax?
The revenue agent does not necessarily get the last word.
If the IRS proposes adjustments that you disagree with, you may have the right to challenge those findings before the IRS Independent Office of Appeals.
This is one reason I begin preparing for a potential appeal while the audit is still underway. The documents produced, facts established, legal arguments developed, and positions taken during the examination can affect the case later.
Depending on the procedural posture, the IRS may issue a 30-day letter allowing the taxpayer to request administrative review.
If the dispute remains unresolved and the IRS issues a Statutory Notice of Deficiency, the taxpayer generally has a limited period to petition the United States Tax Court without first paying the disputed deficiency.
Those deadlines matter.
If you have received an examination report, 30-day letter, or Notice of Deficiency, contact an IRS audit attorney promptly.
When Should You Hire an IRS Audit Attorney?
Ideally, before providing substantive information to the IRS.
Attorney representation is particularly important when:
- A revenue agent has been assigned
- Significant additional tax is at stake
- Multiple tax years are under examination
- A business is being audited
- The IRS is reviewing bank deposits or unreported income
- Records are incomplete
- Substantial penalties may be asserted
- Payroll or employment taxes are involved
- Related entities are being examined
- The IRS wants to interview the taxpayer
- There is concern about potential civil or criminal tax exposure
If the audit has already begun, it may not be too late.
I can enter the examination, review what has already been provided to the IRS, determine where the case stands, and develop a strategy for moving forward.
From IRS Examination to Appeals and Tax Court
An IRS audit should be handled with the possibility of a future dispute in mind.
That does not mean every examination should become adversarial. Many cases can and should be resolved with the revenue agent.
But when the IRS proposes an adjustment that is factually or legally incorrect, the taxpayer should be prepared to challenge it.
My representation can continue from the initial IRS examination through IRS Appeals, audit reconsideration, refund claims, deficiency proceedings, and federal tax litigation, depending on the circumstances of the case.
That continuity matters because decisions made during the audit can affect every stage that follows.
Speak With a Bakersfield IRS Audit Attorney
If you have received an IRS audit notice, you do not have to deal with the IRS by yourself.
Before producing records, speaking with a revenue agent, signing an examination report, or agreeing to additional tax, understand what the IRS is examining and what your options are.
I represent individuals and businesses in Bakersfield, Kern County, and throughout California in IRS audits and examinations.
Contact my office for a confidential consultation about your IRS audit.
I can review the notice, identify the issues under examination, and help you determine the appropriate strategy for responding to the IRS.