Internal Revenue Service Practice and Procedure Deskbook

Internal Revenue Service Practice and Procedure Deskbook provides the thorough legal, procedural, and strategic information attorneys, accountants and other tax professionals need to represent clients more effectively when dealing with the IRS, including guidance on:

• Examinations — including how to deal with IRS document requests, narrow the scope of IRS audits, and reach settlements as part of a correspondence, office or field examination
• Large Business & International Division Examinations — from how to prepare for LB&I examinations to how to use IRS programs to expedite resolutions
• Claims for Refund and Refund Suits — including the effect of the COVID-19 pandemic on refunds and refund suits
• Assessments — with clear coverage of IRS assessment procedures and the Code’s complex mitigation provisions
• Civil Penalties — including steps you can take to abate penalties and minimize the risk of particular penalties being asserted, as well as, a chart containing a detailed summary of the numerous civil penalties listed by Code section
• Tax Fraud — with details on how to make voluntary disclosures to avoid investigations, assemble defense teams, and deploy “good faith” and other defenses
• Appeals — including how to proceed effectively in appeals conferences, as opposed to examinations, and pick the right settlement options for each client
• Litigation — with guidance on how to select the most favorable judicial forum for each case and cope with the Tax Court’s unique rules of practice and procedure
• Collections — from Collection Due Process hearings to surefire solutions to clients’ collection problems