You have been audited and you have received a Revenue Agent’s Report.
You have 30 days from the date you receive the report to appeal the proposed assessments
or a Notice of Assessment will be issued.
The Internal Revenue Service has audited your books and records. It may have been a letter audit, a desk audit or a field audit. Regardless, the examination has been completed and the examiner has issued her report. It is likely that the examiner has alleged in her report that you have not fully complied with the revenue laws and has proposed an assessment of tax and interest together with a variety of penalties.
However, it is possible that the examiner has made a mistake during the audit or that she failed to fully understand or accept the facts or circumstances as presented or that she is simply taking one or more aggressive positions in your audit. The question you face once you have received the Revenue Agent’s Report is simple, what do you do next? While the answer to this question may be more complicated than the question itself, it is important that you decide your next course of action quickly. Generally, you will only have 30 days from the date you receive the Revenue Agent’s Report to file an administrative appeal of the proposed assessments, which in many cases can offer the most economical opportunity for resolution of the proposed assessments.
If you have been working with a representative during the audit, you want to review the Revenue Agent’s Report with your representative to determine if there are any errors that you may want to appeal before a deficiency is assessed.
If you have not been working with a representative during the appeal, you may want to engage a qualified representative to review the Revenue Agent’s Report for errors that you may want to appeal before a deficiency is assessed.
Once you have reviewed the Revenue Agent’s Report with your representative, you may conclude that you do have questions concerning the report that you would like an Internal Revenue Appeals Officer to review. If you have decided to pursue appellate review of the Revenue Agent’s Report, you must decide to whom you will entrust the responsibility of advocating your positions before the Appeals Officer. Your advocate must recognize their primary objective and have the skills and ability to maintain their focus on the primary objective, which is helping you resolve your dispute favorably, economically and professionally through a presentation to and negotiations with the Appeals Officer.
The Bessert Law Firm has the technical expertise, experience and professional decorum you should expect from your advocate as we work together to resolve your questions with the Internal Revenue Service.