During this webinar, Parisa Griess, Shawn O’Brien, and Susan Ryba of our Tax Controversy & Litigation Group shared effective strategies for resolving disputes during IRS examinations and before IRS Appeals, including responding to information document requests (IDRs), navigating statute extensions, and drafting persuasive protests to IRS Appeals.

Top takeaways included:

1. Strategic responses to IDRs can shape the outcome of an IRS examination.
   The session emphasized treating IDRs as advocacy opportunities. A thoughtful and narrative-driven response, tailored to highlight the taxpayer’s position, can steer the examination favorably. Using IDRs to educate the IRS on complex structures of transactions or reorganizations may lead to quicker resolution with no adjustment.
2. Statute of limitations extensions should be approached deliberately.
   Taxpayers should weigh the risks and benefits of granting statute extensions. While extensions will provide the IRS more time for its examination, withholding an extension may prompt faster resolution or prompt the IRS to settle issues. Statute extensions can be used as a strategic lever, especially when audit activity has been limited.
3. Effective protests are key to success in IRS Appeals.
   A protest should be viewed as a legal brief, not just a list of grievances. Effective protests present a compelling narrative, supported by well-documented facts and legal authorities, instead of attacks on the IRS exam team. The goal of the protest should be to demonstrate litigation readiness and influence the IRS Appeals Officer’s view of the case.

Access to the webinar replay is available upon request. Get in touch to learn more.

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