Examinations
The examination from the first contact letter to the closing: information document requests, the assessment statute and extensions, the revenue agent's report, the 30-day letter, the notice of deficiency, and reopening a closed case.
How IRS examinations work: correspondence, office and field audits from first letter to closing
Correspondence, office and field examinations compared: who works them, the opening letters, the IDR and interview stages, and the three ways an exam ends.
Correspondence examinations: how the campus audit runs from Letter 566 to the notice of deficiency
The campus audit by mail: the letters in order, how long each waits, how to get more time, and the point after which Appeals is closed off.
Information document requests (Form 4564) and the IDR enforcement process
How examiners write IDRs, what the IRM requires of them, the LB&I three-step enforcement ladder, and what a sound response looks like.
LB&I examinations: issue-based exams, the acknowledgment of facts and the examination plan
The LB&I examination process in three phases: planning and the exam plan, execution through IDRs, AOF and NOPAs, and resolution through FTS, AIR and Appeals.
The assessment statute of limitations: the three-year rule under IRC 6501 and its exceptions
The three-year assessment period, when it starts, the exceptions that lengthen or remove it, the events that suspend it, and how the IRS tracks the ASED internally.
Form 872 statute extensions: fixed-date, open-ended and restricted consents, and when to refuse
What the IRS must tell your client when it asks for a consent, the forms and their differences, how restricted consents work, and the consequences of saying no.
The revenue agent's report and Form 4549: what the audit report contains and how to respond
The parts of an examination report, which report form goes with which outcome, the transmittal letters, and the rules for extensions, new information and corrected reports.
Signing Form 870 or Form 4549: what agreeing to an examination does and does not do
Agreement forms waive the Tax Court restrictions on assessment, stop interest after 30 days, and leave refund claims and further deficiencies open. Here is the detail.
The notice of deficiency (90-day letter): what it is, how it is mailed and how the Tax Court clock runs
The 90-day letter is the ticket to Tax Court without paying first. Here is how it is issued, what makes it valid, how the deadline is set, and what happens if it passes.
Audit reconsideration: getting the IRS to reopen an assessed examination
The criteria, the cases the IRS will not reopen, the letters the reconsideration unit sends, collection holds, and how to get to Appeals if the request is denied.
Fast Track Settlement: resolving exam issues with an Appeals mediator before the case leaves Examination
FTS puts an Appeals mediator with settlement authority into an open exam. Here is who qualifies, how to apply, what happens at the session, and what is lost if it fails.
Third-party contacts during an exam: the IRC 7602(c) notice, Letter 3164 and the contact list
The IRS must give 45 days' notice before contacting third parties and keep a record you can ask for. Here is what counts, the exceptions, and how to use the rule.
IRS summonses in an examination: when examiners use them, the limits, and how enforcement works
A summons is the step after an ignored IDR. Here is when examiners issue one, the statutory limits, third-party notice and quash rights, privileges, and court enforcement.
Taxpayer interviews, recordings and the right to representation under IRC 7521
When an interview must stop, whether the client has to attend, how recording works, and the limits on financial status techniques, from IRC 7521 and IRM 4.10.3.
Amended returns, qualified amended returns and refund claims during an examination
The qualified amended return cutoff, how examiners handle amended returns and claims filed mid-exam, the LB&I 30-day window, and protecting the refund statute.
No-change reports, partial agreements and closing an IRS examination
The closing letters for each outcome, how partial agreements are built, what happens when a 30-day letter goes unanswered, and the limits on reopening a closed year.
Employment tax examinations and worker classification: Section 530, IRC 3509, CSP and Tax Court review
Worker classification exams step by step: Section 530 first, then the control test, reduced IRC 3509 rates, CSP settlement offers, agreement forms and Tax Court review.
Getting the examiner's file: the activity record, workpapers and FOIA requests
Taxpayers can get most of their exam file without FOIA. Here is what is in it, what the IRS withholds, and how to use FOIA when the direct route fails.
ERC examinations: Letter 6612, what the IDR asks for, the recapture letters, and the six-year assessment statute
The ERC audit from the examiner's side: how claims are classified, what documents the IDR demands for each eligibility test, how a paid credit is recaptured, and the extended statute that keeps 2021 quarters open.
Substitute for return under IRC 6020(b) and the Automated Substitute for Return (ASFR) program: how the IRS builds a return for a nonfiler, and how to unwind it
What an IRC 6020(b) return is, how the ASFR program computes it from information returns, what the CP2566 and CP3219N letters start, and how a late-filed return or reconsideration replaces the default assessment.
Protective refund claims: when a contingency justifies one, what the IRS requires it to say, the deadline and the lookback, and what happens after it is filed
The IRM's four requirements for a valid protective claim, the IRC 6511 deadline and lookback, the forms (1040-X, 1120-X, 843, Schedule PC), the supplemental-claim trap, and how Exam Classification holds the claim until the contingency resolves.
Tentative refunds on Form 1045 and Form 1139: the IRC 6411 application, the 12-month filing window, the 90-day processing rule and how a tentative allowance is clawed back
What an application for tentative refund is and is not, the carrybacks that still exist, the deadlines on both sides, what the IRS checks before paying, and why a paid tentative refund can be reassessed without deficiency procedures.
Forms, tools and templates
Form 872
The fixed-date consent that extends the assessment statute: each element of the form, signature rules, restricted and open-ended alternatives, and the IRS procedures in IRM 25.6.22.
Form 870
The exam waiver that lets the IRS assess an agreed deficiency: when it is used instead of Form 4549, partial agreements, interest effects and what signing gives up.
Statute date calculator
Works out the assessment, collection and refund statute dates from the filing, assessment and payment dates, with the suspensions you enter merged the way the IRM requires.
IDR response cover letter
A cover letter and index that answer an IDR item by item, flag partial responses with dates, and ask the examiner to confirm the IDR is closed.