Gain real-world IRS audit strategies, Circular 230 tips, and insights to protect clients and your practice.
A diverse and wide range of professionals represent clients before the IRS, resulting in varying approaches to different topics and issues. This presentation offers practical, real-world guidance for professionals navigating the complexities of IRS field audits. Attendees will walk away with a clearer understanding of what it means to ‘practice’ before the IRS, how to stay compliant with Circular 230, and how to recognize situations that may require outside support for non-attorney representatives. You’ll also gain valuable insights into managing all stages of a field audit - from properly executing Form 2848 to handling IDRs, taxpayer interviews, and even summons enforcement. The presentation also offers special insights into BBA partnership audits to help you better assist individual clients caught up in a centralized-partnership audit. This session will leave you better equipped to protect your clients and your practice by discussing oft-overlooked procedural pitfalls. Whether you’re new to IRS representation or a seasoned practitioner, the strategies discussed will help you manage risk and maximize audit outcomes.Learning Objectives
- You will be able to explain to taxpayers under audit the process of the audit from beginning to end and assist them in defending themselves in interviews, physical inspections, and IRS information gathering.
- You will be able to identify privileged information and understand how to deal with the same.
- You will be able to describe to a client involved in a BBA centralized partnership audit their rights, obligations, and what to expect from such audit.
- You will be able to recognize ethical limitations on non-attorney representation of clients in IRS Field audits.
Agenda
Ethical Considerations When Practicing Before the IRS
Field Audit Early Stages
Field Audit Information Gathering (Middle Stages)
BBA Specific Topics
Other Field Audit Considerations
Speaker(s)
Sidney W. Jackson, IVDentons Sirote
- Sidney Jackson
- Senior Managing Associate - Tax Controversy Attorney
- Practice focuses on all phases of federal and state tax controversies, including IRS audit, administrative appeals, and court proceedings in the U.S. Tax Court, the United States Court of Federal Claims, the United States Court of Appeals for the 11th Circuit, federal district courts, and state tax tribunals.
- Spoken at various events including the following: An annual Speaker on ‘Tax Practitioner Ethics and Responsibilities’ for local accounting firms in Birmingham, AL, A Lorman presenter for the ‘Reducing IRS Tax Penalties’ course, a panelist for the ‘2023 Updates on Legal, Appraisal, Accounting and Ethical Issues seminar for the Georgia Alabama Land Trust 2023 Conservation Easement, and co-speaker on ‘How Circular 230, Preparer Penalties & Professional Responsibilities Shape Tax Practice’ course for the Alabama Federal & State Tax Institute in 2024
- Alabama State Bar; Freshwater Land Trust Junior Board (2025).
- J.D., Cumberland School of Law (Samford University); LLM, New York University
