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IRS Audit - Should Client Talk to IRS?

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    #16
    Try section 7521 (c)

    Got my CSEA newsletter today. Interestingly enough it had an article about four Revenue agents who were reprimanded for demanding this very scenario.

    Section is as follows: Note that the use of "in the absence of an administrative summons" is an operative here.

    Per section 7521 (c):
    Any attorney, certified public accountant, enrolled agent, enrolled actuary, or any other person permitted to represent the taxpayer before the Internal Revenue Service who is not disbarred or suspended from practice before the Internal Revenue Service and who has a written power of attorney executed by the taxpayer may be authorized by such taxpayer to represent the taxpayer in any interview described in subsection (a). An officer or employee of the Internal Revenue Service may not require a taxpayer to accompany the representative in the absence of an administrative summons issued to the taxpayer under subchapter A of chapter 78. Such an officer or employee, with the consent of the immediate supervisor of such officer or employee, may notify the taxpayer directly that such officer or employee believes such representative is responsible for unreasonable delay or hindrance of an Internal Revenue Service examination or investigation of the taxpayer.

    Source for entire section 7521 quote: http://www.law.cornell.edu/uscode/ht...1----000-.html

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