IRS Tax Audit Defense
Last updated on October 21, 2026
The Atlanta tax attorneys at our law firm represent clients with tax disputes at every level in audit and administrative appeal, as well as the U.S. Tax Court or the U.S. District Court when needed. We represent individual and business clients throughout metro Atlanta and North Georgia who are seeking IRS and state tax debt relief. We place a very high priority on getting every client the best result.
If you have received a notice of tax examination or Notice of Deficiency from the IRS, contact an experienced Atlanta, Georgia, tax lawyer at our firm to schedule an immediate appointment.
We also handle audits and adjustments related to syndicated conservation easement deductions.
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What Happens When You Receive An IRS Audit Notice?
Once the IRS sends an audit notice, an examiner reviews your records for undocumented deductions or income issues. You have the right to representation before responding, and how you handle Information Document Requests (IDRs) can determine whether your case resolves quickly or escalates toward appeals and litigation. If you’ve received an IRS audit notice or an IDR, contact our office before responding to ensure the best outcome for your case.
The IRS Audit Defense Process, Step By Step
Knowing where your case stands can make a stressful situation easier to handle. Here’s how an IRS audit typically unfolds:
- Audit notice: You receive a formal audit notification letter from the IRS. This is often the most stressful part of the process, especially before you understand what comes next.
- Document Request (IDRs): The IRS auditor requests specific documentation. We meet directly with the auditor and manage all IDR responses to control exactly what information is provided.
- Proposed assessment and negotiation: The IRS issues a proposed assessment. We negotiate directly with the auditor, often over multiple rounds, to challenge findings before anything becomes final.
- Administrative appeals: If the audit isn’t resolved at the examination level, the case moves to the IRS Administrative Appeals division. Based on our experience, the large majority of cases resolve at this stage to our clients’ satisfaction.
- Notice of Deficiency (The 90-day letter): If Appeals doesn’t resolve the case, the IRS issues a formal Notice of Deficiency. Under IRC § 6213(a), you have a strict 90-day window to petition the U.S. Tax Court, and this deadline cannot be extended.
- Tax court settlement or trial: Once your case is docketed in Tax Court, an IRS Settlement Officer or counsel attorney typically works to resolve it. More than 99% of docketed Tax Court cases settle without a trial, since the IRS rarely wants to litigate, particularly given that only 19 Tax Court judges nationwide serve the entire country. If your case does go to trial, our firm handles the litigation directly before the U.S. Tax Court.
Knowing which stage you’re in helps you understand what to expect next and what’s still negotiable.
The Burden Of Proof Is On You, Not The IRS
In criminal and most civil cases, the government has to prove its case. In tax law, that’s reversed. The burden falls on you to prove your expenses and deductions with proper documentation. Because you’re the one who has to make the case, having an experienced tax litigation team in your corner isn’t optional; it’s essential.
Why Hire Our Firm For Your IRS Audit
A few things set our approach apart when it comes to defending an audit or dispute:
A Former IRS Counsel Advantage
Cal Bomar previously served as a trial attorney for the IRS Office of Chief Counsel. That experience means he understands the internal guidelines, settlement formulas and trial thresholds IRS attorneys actually use to evaluate a case’s risk. That insight shapes how we negotiate on your behalf from day one.
Regional Volume And Experience
Our firm handles more tax controversy and litigation cases than almost any other firm in the Southeast, bringing decades of combined experience to every audit we take on.
Together, these factors give you a real advantage the moment your case lands on an auditor’s desk.
Determined Defense For IRS And Georgia Tax Audits
An IRS audit, in some cases, will only be a paper audit. In other cases, the IRS will conduct an in-person audit at your office or the IRS office. The examiner will look through your books for expenses and deductions that can be “disallowed” because they haven’t been thoroughly documented. A lack of convenient documentation does not mean the deduction cannot be proven. We will help you reconstruct your business or personal tax records in the best manner possible, use other methods to substantiate a deduction and prevail on the disputed items.
Our team of experienced tax litigators, including a former tax attorney for the IRS Office of Chief Counsel, has insight into what the IRS position will be on a wide range of tax cases, allowing us to effectively negotiate on your behalf to resolve IRS audit disputes. We often deal with:
- Businesses facing audits red flagged for operating at a loss
- Individuals with high incomes undergoing an audit
- Audits of individuals who have received foreign gifts
- Employee retention tax credit audits
The priority is to show that the items attacked are not owed. Even in cases where some taxes are owed, there are relief options, such as:
- Installment agreements
- An offer in compromise
- Penalty abatement
- Reclassification to “currently not collectible” status
- Fresh start relief
Which option makes sense for you depends entirely on the specifics of your case, something we’ll walk through together.
Contact Us Before Responding To An IDR
Once the IRS sends an Information Document Request, how you respond can shape the entire trajectory of your case. Providing more information than necessary, or answering informally without counsel, can accidentally waive rights or hand the IRS documentation that strengthens its position. Before you respond to any IDR, contact our office so we can control what’s disclosed and how.
Do Not Risk Representing Yourself In An Audit
Most taxpayers are at a significant disadvantage when they come up against IRS agents. Agents are trained to interrogate taxpayers in order to uncover financial wrongdoing and honest errors. Any statements that you make to an IRS agent can and will be used as an admission by you.
You do not need to suffer abusive treatment by an examiner. We can appear at the audit on your behalf. We can work with the auditor to arrive at a settlement. If we cannot agree, our firm can represent you throughout the appeals process.
Attorney-Client Privilege
Remember, your conversations with your Atlanta, Georgia, tax attorney are protected by attorney-client privilege.
Contact Us
To avoid an IRS or Georgia tax lien, a bank levy and the compounding of interest and penalties for money owed, contact us to speak directly about your specific tax case. We also handle cases involving syndicated conservation easement IRS audits and litigation, settlement and tax relief.
Our office is located in Atlanta, Georgia. Contact us by calling us at 404-841-6561 or emailing us to schedule your free consultation to discuss your case with an experienced tax lawyer.