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Tax Controversy / Audit Representation

IRS audit representation. A considered response at every step.

An audit notice calls for a clear understanding of the issues and a structured response. We provide senior-led IRS audit representation for high-net-worth individuals and businesses, bringing document review, examination strategy and direct representation into one coordinated engagement.

Representation at a glance

ScopeIRS and state examinations
Starting pointNotice or examination
EngagementSenior practitioner-led

The notice is the starting point. The facts shape the response.

An examination may focus on a specific item or connected questions. The response starts with understanding what the taxing authority is reviewing, which records it has requested and how those records support the reported position.

We review the documentation and develop a strategy around the facts. Our work covers correspondence, office and field examinations, with senior practitioners leading the representation.

What we consider

The notice and scope of review

We review the notice, tax periods and issues under examination. This establishes the starting point and organizes the response around the questions actually being raised.

Records and supporting evidence

We examine supporting documents and identify information needed to develop the response. Document review and a position memo connect the evidence with the issues under examination.

Representation and communications

With your authorization, we file the appropriate power of attorney so our practitioners can represent you in the matters covered by that authorization. Senior-led representation connects communications with the examiner to the documented response strategy.

Resolution and the next path

We assess the findings and available next steps. Depending on the facts and applicable procedures, those may include concluding the examination, seeking penalty relief or pursuing an appeal.

A structured defense sequence

Our engagement follows the defense sequence outlined in our Tax Controversy practice, with the work shaped by the issues and procedural stage of the matter.

01

Notice intake

Review the incoming notice, identify the scope and establish the representation and confidentiality framework.

02

Evidence build

Review the documents and develop a position memo around the issues under examination.

03

Negotiation

Represent the matter with the examiner or, where appropriate, through the appeals process.

04

Resolution

Determine the available conclusion or next path, which may include closure, abatement or an appeal.

Representation in context

These illustrative situations show the questions an audit representation engagement may address. They are hypothetical examples, not client results.

A business owner facing an examination

An examination raises questions about reported income or deductions. The review centers on the requested records and how personal and business information connects to the items under examination.

An investor with several income sources

An audit involves income reported across investments and other activities. The response requires a consistent view of the relevant returns, statements and supporting records.

A corporation responding to document requests

An examination includes requests for business records. The response starts with the scope of the requests and the consistency of the documentation supporting the reported positions.

Explore tax controversy and dispute resolution.

A taxpayer disputing proposed adjustments

The examiner proposes changes the taxpayer disagrees with. The questions include what evidence supports the position and which resolution or appeal procedures remain available.

Frequently Asked

Questions about IRS audit representation

Common questions about audit representation engagements — what the work involves, what to bring, state examinations, and outcomes.

Engagement Intake

Give the next response a clear direction.

Bring your audit notice or examination questions into a confidential strategy conversation. We can review the issues, the stage of the matter and the available records, then determine the appropriate representation.

Schedule Strategy Session
At least $250,000 in dispute requiredConfidential intake
Neil Jesani Advisors

We design dynamic tax strategies for ultra-high-net-worth individuals, founders, investors, business owners, and corporations.

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Circular 230 Notice: Information presented on this site is provided for general informational and educational purposes only and does not constitute tax, legal, accounting, or investment advice. No advisor-client relationship is created by use of this site or by submitting an inquiry. Any tax advice contained herein is not intended or written to be used, and cannot be used, by any taxpayer for the purpose of avoiding tax-related penalties. Representative outcomes reflect prior client work under specific facts and are not a guarantee of comparable results. See our full disclosures.

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