>>> FORMER IRS ATTORNEY --- PATRICK T. SHEEHAN >>>

>>> SERVICES: AUDITS AND AUDIT RECONSIDERATION   >>>        

>>> IRS COLLECTION EFFORTS

>>> COLLECTION - INDIVIDUAL

>>> COLLECTION - BUSINESS

>>> OFFER IN COMPROMISE

>>> PAY OVER TIME/INSTALLMENT AGREEMENT

>>> INNOCENT SPOUSE RELIEF

>>> REQUEST FOR PENALTY ABATEMENT BASED UPON REASONABLE CAUSE

>>> DEEMED UNCOLLECTIBLE

>>> TRUST FUND RECOVERY PENALTY

>>> AUDITS AND AUDIT RECONSIDERATION

>>> STATUTE OF LIMITATION

>>> BANKRUPTCY

>>> JURISDICTION OF FEDERAL COURTS / TAX LITIGATION

>>> IRS NOTICES



THE IRS MAY AUDIT a tax return for any number of reasons. An item on a tax return may draw the scrutiny of the IRS or a tax return may simply be selected for a random audit. Regardless of the reason a tax return is audited, the audit process is one fraught with danger for the unrepresented taxpayer. An audit is a lengthy and in-depth examination of a taxpayer's tax return. Additional information and detailed explanations are generally required, and additional years may be examined.

The IRS generally has three years after a tax return is filed to audit that tax return and to assess additional tax. However, if there is a substantial omission of gross income on the tax return (25% or more), the IRS has six years after the tax return is filed to audit that tax return and to assess additional tax. Finally, the IRS can assess tax at any time if no tax return is filed, or if there is fraud or an attempt to evade the tax on the return that was filed. The IRS may also issue a Notice of Deficiency

At the conclusion of the audit the IRS may propose additional tax, penalties and interest. However, the taxpayer still has an opportunity to contest the audit deficiency. The IRS may also issue a Notice of Deficiency.

If the taxpayer missed the audit or was poorly represented, Patrick T. Sheehan & Associates, Attorneys at Law, P.C., will contact the IRS and attempt to establish a basis for an audit reconsideration. The IRS has the ability to recommend that an audit reconsideration be granted.

If granted an audit reconsideration, the taxpayer will be given the opportunity to present the necessary documentation to substantiate the items contained on his or her tax return. If successful, the IRS will abate all or part of the audit deficiency, including penalties and interest, that was previously assessed. Patrick T. Sheehan & Associates, Attorneys at Law, P.C. has successfully represented many taxpayers in audits and has been able to obtain audit reconsiderations in many cases since its inception in 1991. Patrick T. Sheehan & Associates, Attorneys at Law, P.C., builds upon its past successes and has developed an audit reconsideration program that promotes positive results for our clients. If the IRS has issued a Notice of Deficiency, please call us.

If you have been notified that you will be audited, have been audited but the taxes have not yet been assessed, or recently have been audited and believe that the IRS' audit figures are incorrect, please call us.

We can help. Call us before the IRS calls you! ®



 

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