IRS Audits & Appeals in California
An IRS examination can put several years of financial decisions under review. A useful response starts with the actual notice, the tax periods involved and the information the IRS is requesting. A disagreement about an expense, payment or transaction should be supported by a clear record and a reasoned legal position.
RV Litigation Group PC assists California individuals and businesses with IRS audit responses and administrative tax disputes. We organize the issues, review proposed adjustments and address the steps needed to preserve available appeal rights.
Understand the Examination Before Responding
An audit does not itself establish that a taxpayer has done something wrong. The IRS may conduct an examination through correspondence or an in-person review. The response should be matched to the specific issues and records requested. The IRS audit overview explains these examination procedures.
We review the notice, relevant returns, supporting records and prior communications before preparing a response. For a business, that can require reconciling accounting records with the transaction documents and identifying who has reliable knowledge of the facts. Missing records should be identified honestly; assumptions should not be presented as established facts.
Evaluate Each Proposed Adjustment
Income and transaction treatment
A dispute may concern how a payment was characterized, when income was recognized or which taxpayer reported an item. The legal analysis should follow the underlying transaction and the available evidence.
Deductions and supporting records
The question may be whether an expense qualifies, whether the amount is correct or whether the documentation is adequate. We identify which issue the IRS is actually raising and develop the response around it.
Penalties and related exposure
A proposed tax adjustment and a penalty require separate attention. We review the stated basis for a penalty and whether the facts support a challenge or an available relief request, without promising that relief will be granted.
Administrative Appeals and Court Deadlines
The IRS Independent Office of Appeals reviews qualifying disputes separately from the examination function. A persuasive submission identifies the disputed findings, explains the relevant facts and law, and supports the requested changes. Eligibility and submission requirements depend on the notice and the procedural stage. See IRS guidance on considering an appeal.
An administrative discussion does not replace a required court filing. If a notice of deficiency or another notice carrying court rights arrives, its deadline needs separate attention. Matters that require a petition or judicial review are addressed through our Tax Litigation & Appeals practice.
A Practical Example
The IRS questions a business deduction because the records submitted do not explain the commercial purpose of a payment. A response may require the contract, invoices and contemporaneous business records rather than another copy of the return. If the disagreement continues, those same facts need to be organized into a clear statement of the disputed issue.
This hypothetical illustrates an issue; it is not a description of a firm case or result.
How We Help
Assess the notice and the deadlines
We identify the agency contact, tax periods, requested response and current procedural stage.
Develop a documented response
We work with the client and appropriate accounting advisers to distinguish supported facts, missing information and legal disagreements.
Evaluate the next decision
We explain the available response, administrative appeal or litigation options and the implications of any proposed agreement.
Frequently Asked Questions
No. An examination is a review of the return and supporting information; it is not itself a criminal charge. If questions about intentional conduct, altered records or criminal investigators arise, those issues require a separate assessment of criminal tax exposure.
Yes, where appropriate to the engagement. The accountant may have important records and knowledge of the return, while counsel evaluates the legal dispute and procedural options. Roles, authorizations and the handling of sensitive information should be established at the outset.
Discussions may continue, but they should not be treated as extending a petition deadline. Counsel needs to review the notice immediately and determine whether a separate filing is required to preserve court review. Keep the complete notice and evidence of when and how it was received.
Some matters require a focused review of Tax Penalty Relief, Payroll Tax Disputes or Tax Liens, Levies & Collection Appeals, each with its own factual and procedural questions.
