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Managing Tax Audits and Appeals
2025 Edition
Chapters: Tax Controversy Lifecycle
Crowell & Moring LLP’s Tax Group is pleased to present this microsite, “Managing Tax Audits and Appeals,” a comprehensive overview of IRS audit processes and potential strategies for prevailing in tax controversies and litigation. In the following chapters, you’ll find detailed discussions about relevant case law, step-by-step explanations of filing requirements, and insight about both state and federal compliance programs.
We are excited to offer this resource in an electronic format for the first time. With better search functionality, this user-friendly version is easier to navigate than our traditional paperback book. Now, we are expanding access to the important information that our tax lawyers have compiled and offering a more efficient way to interact with the material.
The new format coincides with larger changes at Crowell’s Tax Group. In another first for our practice, not one, but two women are at the helm, serving as co-chairs. Under this new leadership, which took effect in 2023, our lawyers are well-versed about the perfect storm of challenges on the horizon: businesses are facing increasingly complex U.S. tax regulations, and agencies have been bolstered by record investment in enforcement actions.
It’s more important than ever to have reliable information available at your fingertips, and we are proud to bring you this thorough guide. We hope this microsite becomes a valuable companion in your tax research and practice.
Effective transaction planning is not just about closing the deal, but it is also about preparing for the possibility of IRS scrutiny. Taxpayers cannot always predict which elements of a complex transaction will draw the IRS’s attention. That is why proactive tax controversy risk management must be embedded in the transaction planning process. Companies should continually monitor IRS campaigns and the broader enforcement environment, to identify sensitive return positions and understand which industries, structures, and transaction types are under heightened scrutiny. Strong preparation places taxpayers in the best position if exam issues arise. That means making appropriate disclosures, preserving contemporaneous documentation, protecting privileged communications, and aligning internal stakeholders. A proactive approach in conjunction with a disciplined transaction record provides the best insurance against audit risk and provides strategic advantages in defending return positions during examination. The sections that follow outline practical steps that every company should consider when planning significant corporate transactions. Sign up here for the latest updates.Chapter 1: Planning and Filing Considerations
Chapters 2–4 Coming soon!
