More Facts Resolve Tax Risks –

Aiming toward a Letter of Findings –

IDEALLY THE TAXPAYER’S representatives should attempt to establish a high-level relationship with representatives from the IRS. In so doing, an introductory meeting should be convened wherein the representatives discuss the way forward and the amicable approach they intend to adopt.

This is also an important forum for the taxpayer to emphasize that a letter of findings must be issued by the IRS prior to any assessments and that the taxpayer be given reasonable opportunity to respond to the letter of findings.

The basis of the relationship is one of constant interaction so that if the IRS requires additional information and/or documentation, the IRS should request same from the taxpayer instead of arriving at inferences without first obtaining concrete evidence.

In accordance with Circular 230 Disclosure