IRS Procedures: Examinations and Appeals (Portfolio 623)

Keith M. Jones

Managing Director, WNTS

PricewaterhouseCoopers LLP

Kevin Curran

Managing Director, Tax Controversy and Regulatory Services

PricewaterhouseCoopers LLP

Michael Urban

Managing Director, Managing Accounts

PricewaterhouseCoopers LLP

At a glance

I. Introduction
II. Examinations: Basic Procedures
III. Collateral Procedures
IV. Appeals
V. Refund Claims: Examination and Appeal Procedures

Abstract

Bloomberg Tax Portfolio, IRS Procedures: Examinations and Appeals, No. 623, describes and discusses the law applicable to, and the policies and procedures followed by, the IRS in the examination of tax returns and administrative appeals of examination determinations.

It reviews the general structure and procedures involved in the examination and appeals process, including the procedures for selecting tax returns for examination, the nature, scope and conduct of campus and area office examinations, and the issuance of examination reports.

The Portfolio also describes and discusses collateral examination procedures, including the investigative and summons powers of the IRS, requests for technical advice from the IRS National Headquarters, consents to extend the period of limitations and special areas relating to penalties, jeopardy assessments and bankruptcies. Finally, the procedures and distinctive features involved in the examination and appeal of claims for refunds are discussed.

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