Specific Types of Representation · Representing a Taxpayer in Audits/Examinations

Steps in the process

An examination has a shape that does not vary much: a return is selected, the taxpayer is notified by mail, the audit runs in one of three ways, and it closes in one of three ways. Knowing which split a fact pattern tests usually answers the question.

The rule

Selection (IRS, IRS audits). Selection “does not always suggest there’s a problem,” and the IRS names two methods:

• Random selection and computer screening — returns selected “based solely on a statistical formula,” comparing the return against norms for similar returns, those norms developed from audits of a statistically valid random sample under the National Research Program.
• Related examinations — returns selected because they “involve issues or transactions with other taxpayers, such as business partners or investors, whose returns were selected for audit.”

Two points the page makes expressly: filing an amended return does not affect the selection process of the original return, though the amended return is separately screened and may itself be selected; and a refund is not necessarily a trigger for an audit.

Notification. “Should your account be selected for audit, we will notify you by mail. We won’t initiate an audit by telephone.”

How the audit is conducted. See the figures table for the three types. Where the audit is by mail, the letter “will request additional information about certain items shown on the tax return such as income, expenses, and itemized deductions” — and a taxpayer with too many books or records to mail can request a face-to-face audit.

The initial interview. Where the examination is in person, IRC § 7521(b)(1)(A) requires an IRS officer or employee, before or at an initial interview, to give the taxpayer “an explanation of the audit process and the taxpayer’s rights under such process.” Two further safeguards attach to any interview: if the taxpayer clearly states a wish to consult a representative, the officer shall suspend the interview — “regardless of whether the taxpayer may have answered one or more questions” (IRC § 7521(b)(2)); and a representative holding a written power of attorney who is not disbarred or suspended may appear alone, because the IRS “may not require a taxpayer to accompany the representative” absent a summons (IRC § 7521(c)). None of this applies to criminal investigations (IRC § 7521(d)). The taxpayer may also audio record an in-person interview on advance request, at their own expense and with their own equipment (IRC § 7521(a)(1)).

What the taxpayer must provide. The IRS provides a written request for the specific documents it wants. It accepts some electronic records in lieu of or in addition to other types, and the taxpayer should ask the auditor what is acceptable. Records must be kept for the period in the figures table.

Extensions of time to respond. For an audit by mail, the request goes by fax or mail to the number or address on the letter, and the IRS “can ordinarily grant you a one-time automatic 30-day extension.” But once a notice of deficiency has issued by certified mail (IRC § 6212), no additional time can be granted for supporting documentation, and the 90-day period to petition the Tax Court cannot be extended (IRC § 6213(a)). For an in-person audit, the request goes to the assigned auditor, and if necessary to the auditor’s manager.

Failure to respond. If the IRS does not hear from the taxpayer by the date on the letter, it “will complete our audit and send you an audit report with our proposed changes.” Silence does not pause the examination.

How far back. See the figures table; the underlying assessment period is statutory (IRC § 6501). The page also notes that the IRS “tries to audit tax returns as soon as possible after they are filed,” and that where an audit is unresolved the IRS may request extending the statute of limitations for assessment — which “gives you more time to provide further documentation to support your position.”

How an audit concludes. “An audit can be concluded in three ways”:

1. No change — “an audit in which you have substantiated all of the items being reviewed and results in no changes.”
2. Agreed — “an audit where the IRS proposed changes and you understand and agree with the changes.”
3. Disagreed — “an audit where the IRS has proposed changes and you understand but disagree with the changes.”

If the taxpayer agrees, they are asked to sign the examination report or a similar form, depending on the type of audit.

If the taxpayer disagrees, three routes are named: request a conference with an IRS manager; use mediation — alternative dispute resolution; or file an appeal, “if there is enough time remaining on the statute of limitations.”

Current figures

How it works in practice

Initial contact is always by mail. This is the most useful operational fact in the topic, and it is stated flatly: the IRS “won’t initiate an audit by telephone.” A first contact by phone claiming to open an examination is not the IRS. It is also why the address of record matters — an examination can proceed on notices sent to a stale one.

The three types differ in where, not in law. A correspondence audit is by mail and is typically confined to specific items — income, expenses, itemised deductions. An office audit is an in-person interview at an IRS office; a field audit, one at the taxpayer’s home, place of business, or the representative’s office. The examination powers are the same in each; what changes is the setting and, in practice, the scope.

Note the taxpayer’s own lever: where there are too many books or records to mail, the taxpayer can request a face-to-face audit. A mail audit that cannot accommodate the volume of records tends to close on the documents the IRS happens to have.

Extensions are asymmetric. A mail audit gets a one-time automatic 30-day extension on request. An in-person audit has no such automatic rule; the request goes to the auditor and then to the manager. The whole extension apparatus stops once a notice of deficiency issues: no more time for documents, and the 90-day Tax Court petition period cannot be extended at all. A representative who lets that conversation run past the notice of deficiency has lost the only deadline that cannot be recovered.

Consenting to extend the limitation period cuts both ways, and the IRS says so. It gives the taxpayer “more time to provide further documentation to support your position,” which is why a blanket refusal is rarely the right advice. Where the alternative is the IRS closing on the record as it stands and issuing a notice of deficiency, a consent that buys time to substantiate is often the better outcome.

Learn the three conclusions by their definitions, not their names. “No change” means the taxpayer substantiated all of the items being reviewed. “Agreed” and “disagreed” both begin with the IRS having proposed changes the taxpayer understands — the split is only whether the taxpayer agrees. A taxpayer who does not understand them is in neither category yet, and the answer there is the manager conference.

The three disagreement routes are not sequential. A manager conference, mediation, and an appeal are alternatives, and only the appeal carries a condition: enough time remaining on the statute of limitations. Running out of statute forecloses the appeal, not merely delays it.

How this has changed

The IRS page relied on here was last reviewed 17 February 2026. Two features of it reflect changes worth naming.

The disagreement routes now name mediation explicitly. Alternative dispute resolution sits alongside the manager conference and the formal appeal rather than being an obscure alternative to them, and it deserves treating as a first-class option where the dispute is factual rather than legal.

Appeals is now the Independent Office of Appeals. The Taxpayer First Act of 2019 renamed it and put it on a statutory footing. Older material says “Office of Appeals” or “Appeals Division”; the function is the same.

Two things have not changed: the initial-contact-by-mail rule, and the three-way conclusion — no change, agreed, disagreed.

One caution about sourcing. IRM 4.10.2 is not retrievable on irs.gov and IRM 4.10.1, “Overview of Examiner Responsibilities,” does not define the examination types. The taxonomy here comes from the IRS audits page, which states it directly.

Exam focus

Know that initial contact is always by mail: the IRS will not initiate an audit by telephone.

Know the three types — mail, office (at an IRS office), and field (at the taxpayer’s home, place of business, or the representative’s office) — and that a taxpayer with too many records to mail may request a face-to-face audit.

Know the three conclusions: no change requires that all items reviewed were substantiated; agreed and disagreed both start from proposed changes the taxpayer understands.

Know the one-time automatic 30-day extension for mail audits, and that no extension survives a notice of deficiency, including the 90-day petition period.

Know the look-back: generally three years, more where a substantial error is found, usually not more than six.

Know that the audit-process-and-rights explanation is due before or at the initial interview (IRC § 7521(b)(1)(A)), and that a stated wish to consult a representative suspends the interview.

Check yourself

1. How does the IRS first notify a taxpayer that a return has been selected for audit? (A) By telephone (B) By mail (C) By email (D) By a visit from a revenue agent Answer: B. The IRS states that it will notify by mail and that it won’t initiate an audit by telephone.

2. Where is a field audit conducted? (A) At an IRS office (B) By mail (C) At the taxpayer’s home, place of business, or accountant’s or representative’s office (D) At the Independent Office of Appeals Answer: C. An in-person interview at an IRS office is an office audit; by mail is a correspondence audit.

3. Which describes a “no change” conclusion? (A) The IRS proposed changes but withdrew them (B) The taxpayer substantiated all of the items being reviewed (C) The taxpayer agreed with the proposed changes (D) The audit was closed for lack of response Answer: B. “Agreed” and “disagreed” both begin with proposed changes the taxpayer understands.

4. A taxpayer under a mail audit has already used the automatic extension, and a notice of deficiency has now issued. What further time is available? (A) A second automatic 30 days (B) 30 days on the manager’s approval (C) None for documents, and the 90-day Tax Court petition period cannot be extended (D) 90 additional days Answer: C. The extension is one-time and automatic; once the notice of deficiency issues, no additional time for supporting documentation is available.

5. Which condition attaches to filing an appeal after a disagreed examination, but not to a manager conference or mediation? (A) Payment of the proposed deficiency (B) Enough time remaining on the statute of limitations (C) A signed examination report (D) A Form 2848 on file Answer: B. The IRS names the three routes and attaches the statute-of-limitations condition to the appeal.