Is the burden of proof on the IRS during an Audit? It might shock you to learn that the burden of proof in an IRS audit, and in most dealings with the IRS, lies with the U.S. taxpayer, not the IRS. Key Takeaways on Is the Burden of Proof on...
Managing an IRS Correspondence Audit
One of the new realities for U.S. taxpayers includes the responsibility for managing an IRS correspondence audit. What should you do if you are contacted regarding any form of IRS audit? Did you know the present majority of IRS audits are known as "correspondence audits?" What is a correspondence audit,...
The Risk of California FTB Audits is Increasing
Did you know that the risk of California FTB audits is increasing when compared to the trend of IRS audits in 2025? The California Franchise Tax Board, or FTB, has recently invested in advanced data processing systems and AI applications. This, combined with streamlined information sharing with the IRS, Employment...
Substantial Recent Reduction in the IRS Workforce
What does the substantial recent reduction in the IRS mean for U.S. taxpayers and expatriates? How will staff reductions affect the agency’s ability to audit and collect taxes owed by U.S. taxpayers around the world? What impact will the newly confirmed IRS Commissioner have on the agency’s future? According to...
The Statute of Limitations in an IRS Audit
Why is the statute of limitations such an essential factor in an IRS audit? Should you approve a request from the auditor for a waiver of the statute of limitations in an IRS audit? This is often a complex question, and if you are not represented by an experienced tax...
Why You Need a Lawyer for an IRS Audit
Why do you need a lawyer for an IRS audit? Have you received an IRS audit notification (IRS form letter 2205-A, 2205-B, or 566)? What do you need to know? The first step is to download and read our free booklet entitled "What to Expect from an IRS Audit." This...
The Taxpayer Bill of Rights – 10 Essential Rights for U.S. Taxpayers
Are you aware of the Taxpayer Bill of Rights? We are reminded, especially during tax season, that taxpayers have 10 essential rights when dealing with the Internal Revenue Service. The IRS expects its employees to understand and apply taxpayer rights throughout the process of either an IRS audit or an...
An Appeal of an IRS Audit is Based Upon the Audit’s Examination File
Did you know the appeal of an IRS audit is based upon the IRS examination file record of the audit itself? When the IRS produces its "Notice of Determination" at the end of an audit, a very important door closes: the ability to put information onto "the record" to bolster...
What is Willful Blindness According to the IRS?
What is willful blindness according to the IRS? How is this important in tax cases involving unreported or under-reported income, disclosure of offshore assets and income, FinCEN Form 114 (more commonly referred to as an "FBAR"), and even digital currencies and Non-Fungible Tokens (NFTs)? In an internal IRS memorandum from...