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attorney for irs tax audit

IRS Tax Audit Attorney in New Jersey and New York

An IRS audit can lead to additional tax assessments, penalties, interest, tax liens, levies, or broader scrutiny if the facts are mishandled. Securing experienced legal counsel early ensures your audit remains focused, organized, and strategically managed.

Todd S. Unger represents taxpayers during IRS audits, disputed examinations, CP2000 underreported income notices, audit reconsideration claims, and administrative appeals. Our objective is to protect your rights, present defensible documentation, and prevent unnecessary financial escalation.

Do Not Handle a Serious IRS Audit Alone

An IRS audit is far more than a simple request for paperwork. Revenue agents carefully review reported income, expense deductions, bank deposits, business accounting, and prior filing histories. How you respond directly dictates whether the examination closes smoothly or expands into civil fraud penalties, multi-year audits, and enforcement action.

Whether your audit involves a single item, multiple tax years, business deposits, or unfiled returns, the appropriate strategy depends on your notice type, available records, and potential legal exposure. Attorney representation allows you to communicate through counsel, challenge unsupported adjustments, and preserve administrative appeal rights.

IRS Audit Issues We Help With

IRS examinations vary based on tax year, entity type, dollar amount, and specific information requested. Todd S. Unger provides strategic defense across a wide spectrum of audit challenges:

IRS Correspondence Audits
Office & Field Examinations
CP2000 Underreported Income Notices
Missing Records & Substantiation
Business Income & Expense Audits
Crypto, Brokerage & 1099 Discrepancies
Audit Reconsideration Claims
Formal Appeals & Protest Filings

If the IRS has already assessed additional tax following a closed audit, review our guidance on IRS audit reconsideration and Collection Due Process hearings.

Understanding Types of IRS Audits

Each audit type involves distinct procedural rules and scope requirements:

Correspondence Audits

Conducting via mail, these focus on single line items, missing 1099 records, or specific tax credits.

Office Examinations

Conducted at a local IRS office, requiring a taxpayer or attorney to present records directly to an examiner.

Field Audits

Comprehensive, in-person examinations held at your home or business location involving broad record reviews.

Business Audits

Examines corporate income, cash flow, bank deposits, officer compensation, and expense substantiation.

Payroll & Employment Audits

Evaluates worker classifications (W-2 vs. 1099), payroll tax deposits, and Trust Fund Recovery exposure.

CP2000 Notices

Automated computer matching notices flagging discrepancies between tax returns and third-party reports.

An IRS CP2000 notice is an automated proposed adjustment rather than a formal audit. However, failing to properly respond can lead to immediate tax assessments and automated collection action.

What to Do After Receiving an IRS Audit Notice

Your initial steps set the trajectory of the audit. Before making informal statements or submitting partial records, execute this 7-step checklist:

1. Preserve Official Documents: Retain the complete IRS notice, audit questionnaire, and postmarked envelope.
2. Identify Response Deadlines: Note the tax periods examined and strict response windows listed.
3. Evaluate Scope: Determine whether the IRS is conducting a focused document match or a broad field audit.
4. Organize Substantiation: Gather tax returns, bank statements, receipts, 1099s, and accounting ledgers.
5. Avoid Unnecessary Explanations: Do not submit casual written narratives before consulting a tax attorney.
6. Assess Penalty Risks: Identify potential exposure to accuracy-related penalties or unreported income issues.
7. Preserve Appeal Rights: Ensure all procedural windows remain open to challenge unfavorable findings.

How Legal Representation Protects Your Interests

Tax attorney representation goes beyond submitting paperwork—it controls the narrative and limits audit exposure across 9 strategic areas:

Reviewing Audit Notices
Identifying Disputed Items
Communicating with Examiners
Organizing Evidence
Preventing Scope Creep
Responding to IDRs
Challenging Adjustments
Filing Formal Appeals
Pursuing Reconsideration

What Happens After an Unfavorable IRS Audit?

If an audit ends with an unfavorable Examination Report (Form 4549), you retain administrative appeal options before the assessment becomes final. If appeal windows have passed and tax has been assessed, IRS audit reconsideration allows taxpayers to submit new evidence to reopen the examination.

If unpaid audit balances move into automated collections, receiving IRS final notices triggers mandatory statutory rights to a Collection Due Process (CDP) hearing to prevent levies or tax liens.

Frequently Asked Questions

Answers to common questions regarding IRS audit defense, appeals, and CP2000 notices.

Should I hire a tax attorney for an IRS audit?

Yes. If your audit involves substantial balances, missing records, business income, potential accuracy penalties, or unfiled returns, hiring a tax attorney ensures attorney-client privilege and protects you from scope expansion.

What happens if I disagree with the audit findings?

You can file a formal protest with the IRS Office of Appeals, petition the U.S. Tax Court, or request audit reconsideration if new substantiating documents become available after assessment.

Can a civil IRS audit turn into a criminal investigation?

While most audits remain civil, revenue agents who uncover indicators of fraud (such as altered records, false deductions, or double sets of books) must refer cases to IRS Criminal Investigation (CI).

Is an IRS CP2000 notice the same as an audit?

No. A CP2000 is an automated proposed adjustment triggered by a mismatch between your return and 1099/W-2 reports sent to the IRS by third parties. It requires a timely, detailed response to avoid automated assessment.

Speak With an IRS Tax Audit Attorney Today

If you received an IRS audit notice, CP2000 letter, or unfavorable examination report, contact Todd S. Unger, Esq. to protect your rights and defend your position.