Tax Manager — Tax Audit & Controversy
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What you'll learn:
[Description] This day focuses on understanding the initial phases of a tax audit. It covers IRS organization, audit selection criteria, and initial communication with the IRS. - Specific resources or activities: - Review the IRS Internal Revenue Manual (IRM) on audit procedures (especially Parts 4, 5, and 6). Focus on exam process. - Research IRS organizational structure, key personnel (e.g., Revenue Agents, Managers, Appeals Officers), and their roles in audits. Identify which division handles your specific audit. - Analyze real-world audit notices (e.g., CP2000, 3206) and engagement letters. - Consider different types of audits (correspondence, office, field). - Expected outcomes: - Understanding of the different types of audits and IRS organizational structure. - Ability to interpret IRS notices and initial communication. - Knowledge of the factors used by the IRS to select returns for audit.
Personal Notes:
What you'll learn:
[Description] This day centers on proactive planning and risk assessment within the context of an audit. It covers identifying potential audit risks, analyzing relevant documents and financial statements, and developing a preliminary audit strategy. - Specific resources or activities: - Study audit risk assessment methodologies (e.g., inherent risk, control risk, detection risk). - Review relevant tax law (e.g., IRC sections applicable to the audit issues). - Analyze the client's financial statements, tax returns, and supporting documentation to identify potential risks. - Develop a preliminary audit strategy including key areas of focus and a timeline. - Expected outcomes: - Ability to identify and assess potential audit risks. - Proficiency in analyzing financial statements and tax returns for audit purposes. - Ability to develop a preliminary audit strategy.
Personal Notes:
What you'll learn:
[Description] This day emphasizes the importance of documentation and substantiation in tax audits. It involves learning about acceptable documentation requirements, gathering supporting evidence, and preparing responses to IRS inquiries. - Specific resources or activities: - Research acceptable documentation for various tax issues (e.g., deductions, credits, cost of goods sold). Consult IRS guidance documents like the IRS Publication 552. - Review examples of strong and weak documentation supporting various tax positions. - Practice gathering and organizing supporting documents (e.g., invoices, contracts, bank statements, etc.). - Prepare sample responses to IRS information document requests (IDRs). - Expected outcomes: - Understanding of documentation requirements for various tax positions. - Ability to gather, organize, and present supporting evidence effectively. - Proficiency in preparing responses to IRS IDRs.
Personal Notes:
What you'll learn:
[Description] This day covers the negotiation process with the IRS, including settlement strategies, penalty abatement, and the use of offers in compromise. - Specific resources or activities: - Study IRS guidelines on negotiation and settlement (e.g., IRM Section 4.10). - Research penalty abatement procedures and qualification requirements. - Analyze case studies on successful and unsuccessful negotiation strategies. - Learn about offers in compromise (OIC) and their requirements. - Role-play negotiation scenarios with the IRS. - Expected outcomes: - Understanding of negotiation strategies and settlement options with the IRS. - Knowledge of penalty abatement procedures. - Ability to analyze case studies and apply negotiation tactics.
Personal Notes:
What you'll learn:
[Description] This day focuses on the appeals process within the IRS and the option of seeking judicial review. It explores the roles of the IRS Appeals Office, preparing a protest, and understanding the process of filing a lawsuit. - Specific resources or activities: - Study the IRS Appeals process (IRM 8.13). - Research the different courts involved (Tax Court, District Court, Court of Federal Claims). - Analyze the components of a protest to the IRS Appeals Office. - Understand the process of filing a lawsuit in the relevant court. - Review case law related to tax litigation. - Expected outcomes: - Understanding of the IRS Appeals process and its role. - Ability to prepare a protest to the IRS Appeals Office. - Knowledge of the judicial review process and the different courts involved.
Personal Notes:
What you'll learn:
[Description] This day provides detailed insight into tax penalties, including their types, calculation, and defenses. It also covers the statute of limitations for assessments and refunds. - Specific resources or activities: - Review IRC sections related to tax penalties (e.g., 6651, 6662, 6663). - Research defenses against penalties (e.g., reasonable cause, good faith). - Learn about the calculation of various penalties. - Study the statute of limitations for assessing tax and for claiming refunds (IRC 6501, 6511). - Analyze case law related to penalty assessments and challenges. - Expected outcomes: - Understanding of different types of tax penalties and their calculation. - Knowledge of defenses against penalties. - Understanding of the statute of limitations for assessments and refunds.
Personal Notes:
What you'll learn:
[Description] This day covers ethical considerations and professional responsibility related to tax controversy work. It focuses on the ethical obligations of tax professionals and navigating conflicts of interest. - Specific resources or activities: - Review Circular 230 (Regulations Governing Practice Before the IRS). - Study the AICPA Statements on Standards for Tax Services. - Analyze ethical dilemmas commonly encountered in tax controversy. - Discuss conflicts of interest and how to handle them. - Consider examples of disciplinary actions involving tax professionals. - Expected outcomes: - Comprehensive understanding of ethical obligations under Circular 230 and related professional standards. - Ability to identify and resolve ethical dilemmas. - Awareness of the potential consequences of ethical breaches.
Personal Notes:
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