IRS Audit Defense Lawyer

Understanding IRS Notices

An IRS audit almost always begins with a written notice. That notice may be a routine request for supporting documentation, a proposed adjustment based on a mismatch between a return and third-party reporting, or a formal notification that a return has been selected for examination. Reading the notice carefully is the first step, since it identifies the specific tax year and issues at stake, along with the deadline for responding.

Ignoring an IRS notice, or responding incompletely, is one of the most common ways a manageable inquiry turns into a larger dispute. Anthony Girand Law reviews each notice with clients to identify what the IRS is actually asking for and to develop a response that addresses the issue directly.

Correspondence Audits

Correspondence audits are conducted entirely by mail and typically focus on a narrow issue, such as a specific deduction, credit, or item of income. While often less invasive than an in-person audit, correspondence audits still require a precise, well-documented response, since the IRS will generally proceed with a proposed adjustment if the taxpayer does not respond adequately within the stated deadline.

Office Audits

Office audits require the taxpayer, or their representative, to appear in person at an IRS office to answer questions and provide documentation. These audits tend to cover more ground than a correspondence audit and often involve a review of several related items on the return. Preparing for an office audit includes organizing records in advance and anticipating the specific questions an examiner is likely to raise.

Field Audits

Field audits are typically the most extensive form of examination, conducted by an IRS revenue agent at the taxpayer's home, business, or representative's office. Field audits are common for business returns and often examine multiple tax years and issues, including income reporting, expense substantiation, and, for businesses, payroll tax compliance. Anthony Girand Law represents clients directly in dealings with the assigned revenue agent, helping to manage the scope and pace of the examination.

Document Requests and Substantiation

At the center of nearly every audit is the question of substantiation — whether the taxpayer can support the income, deductions, and credits reported on the return with adequate records. The IRS will issue Information Document Requests (IDRs) specifying what it wants to see. Organizing responsive records clearly, and understanding which records are legally sufficient to substantiate a given item, is central to a sound audit strategy.

Audit Strategy

An effective audit strategy accounts for the specific issues raised, the strength of the taxpayer's records, and the realistic range of outcomes. In some cases, the best approach is a direct, well-documented response that resolves the matter quickly. In others, it may be necessary to negotiate the scope of the examination, request additional time, or push back on an examiner's proposed adjustments with legal and factual support. Anthony Girand Law tailors the approach to the specific facts of each audit rather than applying a one-size-fits-all playbook.

Business-Owner Audits

Audits of business owners, founders, and self-employed individuals frequently raise issues beyond those seen in a typical individual audit, including reasonable compensation questions, worker classification between employees and independent contractors, and entity-level reporting requirements. These audits benefit from representation that understands both the tax rules at issue and the operational realities of running a business.

Audit Appeals

When an audit concludes with a proposed adjustment the taxpayer disputes, the next step is often an appeal to the IRS Independent Office of Appeals, a separate function within the IRS intended to resolve disputes without litigation. A well-prepared appeal presents the taxpayer's legal and factual arguments clearly and can often result in a more favorable resolution than the original audit determination.

Connection to Tax Controversy and Tax Court

If an audit and any subsequent appeal do not resolve the matter, the IRS will issue a Notice of Deficiency, giving the taxpayer 90 days to file a petition with the United States Tax Court. Audit defense is closely connected to the firm's broader tax controversy practice, since the strategy adopted during an audit often shapes the options available if the matter proceeds further. Anthony Girand Law represents clients across this full continuum, from the initial IRS notice through appeals and, where necessary, Tax Court litigation.

Working With Anthony Girand, Esq.

Anthony Girand, Esq. is a JD/MBA and Maryland attorney whose practice includes immigration, tax controversy, federal litigation, startup law, and regulatory compliance. He brings a business-minded legal perspective to matters involving federal agencies, founders, professionals, companies, and individuals facing consequential legal decisions.

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