An IRS audit is a dispute with the government over what you owe. It is a legal matter, not an accounting one. Since 2013, Brotman Law has represented 400+ clients in audits — field exams, correspondence audits, office exams, and eggshell audits with criminal exposure underneath. We handle the IRS so you can keep running your business.
By Sam Brotman, JD, LLM, MBA · Last updated August 2026
What kind of audit letter did you get?
The letter tells you how serious this is. A CP2000 is not an audit at all — it is a computer-matching proposal you answer in writing. Letter 566 or a 566-CG opens a correspondence audit on one or two items. Letter 2205 with Form 4564 (an Information Document Request) means a revenue agent has your return — that is a field exam, the full version. Our audit letter guide decodes each one; the response strategy differs sharply by track.
What the auditor is actually testing
Every audit is a documentation contest over a handful of issues, not a trial of your whole life. The IRS selects returns by statistical scoring (DIF), document mismatches, or a related exam — and the agent arrives with specific issues: unreported income, Schedule C expenses, basis, worker classification, credits. The single biggest mistake taxpayers make is over-answering: volunteering years, records, and explanations the IDR never asked for. Under IRC § 7602 the IRS has broad authority to examine records — but the scope of the audit is negotiable, and holding that line is most of the job.
How an IRS audit unfolds
The sequence is: examination, findings, 30-day letter, appeal, then — only if everything fails — Tax Court.
The exam runs on IDRs and interviews. When the agent finishes, you get Form 4549, the examination report, with proposed changes. You do not have to sign it. The 30-day letter that follows gives you the right to protest to the IRS Independent Office of Appeals — a separate body that weighs the hazards of litigation and settles most cases. If Appeals fails, the 90-day Notice of Deficiency starts the Tax Court clock. Most audits we handle end at the exam or Appeals stage; the ones that end badly usually went unrepresented until after the 4549 was signed.
How long does an IRS audit take?
Correspondence audits typically run three to eight months; field exams, twelve to eighteen; either can extend. The IRS generally has three years from filing to assess under IRC § 6501 — six for substantial understatements — and agents will ask you to extend the statute with Form 872 when they run short. Whether to sign, and for how long, is a strategy decision, not a formality.
What we do differently
We treat the audit as the first round of a legal dispute, and we build the record for the rounds after it. That means scoping the IDRs and pushing back on fishing expeditions, preparing every document with Appeals in mind, keeping you out of the interview chair where the law allows it, and spotting criminal exposure early — the eggshell audit — before something gets volunteered that cannot be taken back. If the number is wrong, we contest it; if the number is right, we resolve it on collection terms you can live with.
What does audit representation cost?
It depends on the track: correspondence audits are a fraction of a field exam, and we quote a fee once we have read your letter. What we can tell you up front: representation usually pays for itself in scope control alone — the issues the audit never expands into, the years it never reaches, and the penalties that never get asserted. Accuracy-related penalties run 20% under IRC § 6662, and a defensible reasonable-cause position is often worth more than every deduction in dispute.
Tell us what is going on
Short version is fine. We read every one of these, and you will hear back from a person.