NBAA 2011 Tactics to Avoid and Survive an IRS Audit

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At This Stage EVERYTHING IS NEGOTIABLE If you can’t settle the case at the audit level, then someone is being unreasonable
Supervisor Negotiations • Negotiations become more difficult as the audit progresses • Taxpayer can always request a supervisor meeting • Supervisor is obligated to attend final meeting if taxpayer requests • Strategy: Probably nothing to lose to demand meeting • Make auditor and supervisor aware by your actions that you are prepared to take the case to court if a settlement can’t be reached at Appeals • Always request that supervisor abate penalties
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NBAA 2011 Tactics to Avoid and Surv
Page 3 and 4:
Resource Materials • Copies of to
Page 5 and 6:
Audit Defense - Necessary Elements
Page 7 and 8: Passive Loss Limitations (PAL) IRC
Page 9 and 10: PAL Rules, Exceptions, and Grouping
Page 11 and 12: What to do Before the Audit • Sep
Page 13 and 14: PAL/IRC§ 469 Cases • Leroy Cande
Page 15 and 16: Ordinary and Necessary Business Exp
Page 17 and 18: Ordinary and Necessary Business Exp
Page 19 and 20: What to do Before the Audit • Ana
Page 21 and 22: Aircraft Audit Issues Depreciation
Page 23 and 24: Sec. 280F Listed Property Rules •
Page 25 and 26: Depreciation Rates for Aircraft - M
Page 27 and 28: Bonus Depreciation Issues • Typic
Page 29 and 30: Single-Purpose Companies Have High
Page 31 and 32: What to do During the Audit • Dep
Page 33 and 34: Hobby Loss Rules - IRC §183 • Re
Page 35 and 36: Single Purpose Companies - Audit Ta
Page 37 and 38: Hobby Loss Rules (Continued) • Ta
Page 39 and 40: What to do During the Audit • Rev
Page 41 and 42: Aircraft Audit Issues Personal Use
Page 43 and 44: Personal Use of Company Aircraft
Page 45 and 46: Personal Use Of Company Aircraft -
Page 47 and 48: What to do During the Audit • Exp
Page 49 and 50: Flight Department Company Issue - I
Page 51 and 52: Flight Department Company - How to
Page 53 and 54: What to do Before the Audit • Con
Page 55 and 56: Flight Department Company - Cases P
Page 57: Every Issue Won at Field Audit Leve
Page 61 and 62: 90-Day Letter • If taxpayer does
Page 63 and 64: The Appeals Process • Appeal leve
Page 65 and 66: Advantages in Appealing • Appeals
Page 67 and 68: The Appeals Hearing • Informal co
Page 69 and 70: Fast Track Mediation • Small Busi
Page 71 and 72: COURT OPTIONS
Page 73 and 74: U.S. Tax Court • Once a case is d
Page 75 and 76: Final Points • Be sure to incorpo
Page 77 and 78: Flight Tax Systems, Inc. - Coming S
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NBAA 2011 Tactics to Avoid and Survive an IRS Audit

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