Abstract

Douglas Peck Thompson

This paper presents a discussion of certain procedural issues that confront an individual taxpayer in the United States when dealing with a civil tax audit conducted by the Internal Revenue Service (“IRS”). Given the nature of the topic, the paper cannot address every such issue because the topic is vast and each individual situation is unique. It is, however, the author’s hope that the reader will come away with a deeper understanding of the IRS’ civil tax audit and protest process, along with an appreciation for certain procedural issues related to the resolution of conflicts with the IRS. It is the author’s further hope that this paper will inspire students of accounting and taxation to develop a deeper appreciation for the tactics and techniques used during the civil tax audit and defense process and that these students can utilize this information in their professional careers. Issues pertaining to IRS criminal tax investigations and prosecutions under the Internal Revenue Code of the United States or other related laws are beyond the scope of this paper.