Few things inspire dread more than receiving a notice from the IRS or one of the state tax agencies that it wishes to conduct an audit. The thought of a bureaucrat poring through your personal affairs, particularly if you have taken some aggressive positions on your return, is daunting.

I provide representation from the very start. I speak with you to understand your business or personal situation, to understand the areas of weakness in the return before going in to the auditor and to start building your defenses to possible criticism from him or her. I work with you to organize your documents, help you decide which are necessary to produce and which are not, and often attend the audit in your place, eliminating the need for you to face the auditor directly.

In the less common cases where the auditor may suspect civil fraud or even criminal conduct, it is especially important to plan from the outset. The taxpayer must communicate to me openly and honestly what areas are suspect, keeping in mind that those communications are protected by the attorney-client privilege. In some cases, it is possible to prepare a defense beforehand; in others, silence may be the best option. But we must know this before going into the audit; surprises at audit are a problem and can be the prelude to expanding the scope of the audit or even building a criminal referral.