A critical aspect of tax practice involves – however rare it may be – understanding the investigatory processes of the Internal Revenue Service (and state tax authorities) and how the tax practitioner should respond to summons and subpoenas on those rare occasions when practitioner is confronted with one.
• Recognize the importance of understanding the IRS investigatory process and receipt of a summons or subpoena
• Identify the legal issues involved in responding to the IRS investigatory process
• Determine how to respond to the receipt of a summons or subpoena
• Understand the purpose of summonses and subpoenas
• Understand the legal issues involved in responding to a summons or subpoena
• Understand the client's privilege claims
• Utilizing the Freedom of Information Act provisions in the examination process