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Tag: audit

Answers to Common Questions for IRS CP3219N Notice of Deficiency (90-day letter)

6 November, 2015

What you need to do If you want to challenge the deficiency determination, file a petition with the Tax Court. File your tax return immediately (no later than 90 days from the date of the

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IRS issues new information document request (IDR) directives

14 April, 2014

The IRS’ Large Business & International division has issued a series of directives that streamline its information document request (IDR) process by establishing stricter deadlines and requiring the agency to issue highly specific information requests.

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30-DAY LETTERS VS. 90-DAY LETTERS IN TAX AUDITS

21 June, 2013

In a tax audit situations, the IRS only has a 3 year statute of limitations to assess additional taxes. If the IRS takes too long to initiate an audit, or the audit drags on too

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Audit Beware: IRS’ Global High Wealth Industry Group

18 August, 2011

A recent article in the Wall Street Journal discussed the new IRS’ Global High Wealth Industry Group. Over 1 year ago we warned readers of the new group when Commissioner Shulman announced its formation in

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Post IRS Audit Strategic Options: The IRS’ 30 Day Letter

9 April, 2011

If, after conducting the audit, a taxpayer and revenue agent cannot come to an agreement, the agent will prepare and submit to the taxpayer a preliminary notice of deficiency, or “30-day letter.” The 30-day letter is

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Recent Posts

  • New Penalty Landscape: Analyzing the October 2025 Updates to IRM 21.8.2.19.2 for Late-Filed Forms 3520May 27, 2026
  • Late Disclosure of Foreign Gift for Wedding Results in PenaltyMay 15, 2026
  • Kwong: Preserving Client Claims for COVID-Era Penalty and Interest RefundsMay 13, 2026
  • Internal Revenue Service’s Clarification on Reasonable Cause for Form 5472 PenaltiesMay 12, 2026
  • Defending the Cross-Border Client: Join Parag at the NJSEA Annual Conference This JuneMay 9, 2026

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  • About Patel Law Offices
  • Delinquent FinCen Form 114 (FBAR) Filings
  • Delinquent or unfiled IRS Form 5471

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