IRS Civil Examination Division
By Shad Brown, Attorney
The first, and most likely, division that a person is to encounter is the IRS’ civil exam division. The purpose of the civil examination division is to investigate perceived tax discrepancies and to notify individuals and other entities of the IRS’ proposed deficiencies. These notices will come in a number of forms. During this process, taxpayers will be given an opportunity to respond to the IRS and provide the IRS information they believe will support their position. Taxpayers also have an opportunity to challenge the IRS’ findings with IRS appeals division. Once a final determination has been made, the IRS will send the taxpayer a Notice of Deficiency or what is often referred to as a “90 day letter.” After receiving this letter a taxpayer has 90 days to challenge the IRS’ determination in the United States Tax Court. If a taxpayer has not petitioned the Tax Court in this time, the IRS can then assess the tax, which the IRS determined was owed, and begin collection proceedings against the taxpayer.
Responding to the IRS in a timely manner, and effectively challenging determinations made by the IRS can be daunting task. However, taking advantage of these opportunities as soon as they are provided will provide the best chance for a positive result. For this reason, it is imperative that a taxpayer contact an experienced tax attorney as early as possible to preserve all rights that the taxpayer has to challenge the IRS’ determinations. Whatever your tax problem, the experienced attorneys at the Dana Law Firm can help you in all phases of an IRS audit and can fight the IRS in the United States Tax Court, the United States Court of Federal Claims and the United States District Court for the District of Arizona.