Don't Ignore IRS Formal Document Requests - McDermott Will & Emery

Don’t Ignore IRS Formal Document Requests

Overview


Andrew Roberson and Joshua McConkey wrote this bylined article on the Formal Document Request (FDR) procedures used by the IRS in business audits. The authors cautioned that “taxpayers receiving an FDR should formulate a response within the FDR response period to avoid any potential exclusionary rule effects over foreign-based taxpayer material that might damages their case in a later litigation.”