Tax Controversy & IRS Audit Defense
In today's complex tax environment, businesses and individuals must take every precaution to avoid tax disputes. GreenGrowth CPAs helps you minimize audit risk and manage IRS inquiries at every stage.
Get StartedManage and Mitigate Tax Controversy Risks
In today's complex tax environment, businesses and individuals must take every precaution to avoid tax disputes. The unfortunate fact is that the Internal Revenue Service (IRS) has made sport of auditing and assessing penalties on certain companies.
Everyone from local mom-and-pop cultivators to public multi-state operators has faced serious inquiries from the IRS. Our team of experienced tax controversy professionals has deep experience mitigating future risk and resolving known controversies. Proactive federal tax planning is your strongest defense against future audits, and our state and local tax services cover the same proactive posture across every state where you operate.
No matter what stage of an IRS inquiry you are in, our diligent approach will identify and evaluate current issues, and manage the process efficiently and effectively.
Federal, State and Local Tax Audit Support
Support preparing and documenting a valid tax audit at every level (federal, state, and local), ensuring your business can defend its tax positions with complete and accurate documentation.
Pre-Controversy Audit Readiness
Proactive audit readiness assessment, reviewing your current tax positions, documentation practices, and internal controls to identify and address weaknesses before an IRS inquiry arrives.
IRS Controversy Representation
Direct representation before the IRS during audits, examinations, and appeals, communicating with tax authorities on your behalf and protecting your rights throughout the process.
Tax Authority Settlement Negotiation
Negotiation of tax settlements, offers in compromise, and penalty abatements with federal and state tax authorities, resolving disputes on the most favorable terms available.
Expert Witness Testimony
Expert witness services in tax-related legal proceedings, providing independent, credible testimony on complex tax issues for litigation support and dispute resolution.
Received an IRS notice or audit letter?
Talk with our tax controversy team about your response timeline and the best path forward.
Tax Controversy Services We Provide
IRS Audit Representation
Direct representation before the IRS throughout the audit process, protecting your rights and managing all communications with tax authorities on your behalf.
Audit Readiness
Pre-audit documentation review and preparation, identifying gaps in your tax position support before an IRS or state inquiry begins.
State & Local Audit Defense
Representation and documentation support for state and local tax audits across all jurisdictions, including sales tax, income tax, and excise tax examinations.
Settlement Negotiation
Negotiation of tax settlements, penalty abatements, and offers in compromise with federal and state tax authorities to resolve disputes on favorable terms.
Cannabis Tax Controversy
Specialized IRS controversy support for cannabis operators, including 280E audit defense, documentation preparation, and representation in cannabis-specific federal tax disputes.
Expert Witness Services
Independent expert witness testimony on complex tax issues for litigation and dispute resolution, providing credible, well-documented support in tax-related legal proceedings.
Documentation Is Your Best Defense
The businesses that navigate IRS audits most successfully are the ones that maintained clean, complete, and consistent records before the inquiry arrived. GreenGrowth CPAs helps you build the documentation infrastructure that makes your tax positions defensible at every level.
From COGS documentation for cannabis 280E audits to revenue recognition records for technology companies, our team knows exactly what the IRS looks for and ensures your records are ready before they ask.
Need 280E or specialized audit defense?
Connect with our tax controversy specialists about your industry, documentation, and representation strategy.
Tax Controversy FAQs
What should I do if I receive an IRS notice or audit letter?
Do not ignore it and do not respond without professional guidance. IRS notices have strict response deadlines, and the way you respond to an initial inquiry can significantly affect the outcome of the audit. GreenGrowth CPAs provides immediate consultation for businesses and individuals who receive IRS correspondence, reviewing the notice, advising on the appropriate response, and representing you throughout the process if needed.
Does GreenGrowth CPAs handle cannabis 280E audits?
Yes. GreenGrowth CPAs has specific experience representing cannabis operators in IRS audits related to 280E, the federal tax code that limits business expense deductions for cannabis businesses. 280E audits require specialized expertise: documentation of COGS allocation, entity structure analysis, and defensible positions that hold up under IRS scrutiny. Our team has prepared cannabis operators for and represented them through 280E audits at multiple stages.
What is an offer in compromise and when does it make sense?
An offer in compromise (OIC) allows taxpayers to settle their tax debt with the IRS for less than the full amount owed, when full payment would create economic hardship or when there is genuine doubt about the liability. GreenGrowth CPAs evaluates whether an OIC is appropriate for your situation, prepares the application, and negotiates with the IRS to achieve the best possible settlement outcome.
Can GreenGrowth CPAs represent me before state tax authorities as well as the IRS?
Yes. GreenGrowth CPAs provides controversy representation at the federal, state, and local level, including state income tax audits, sales tax examinations, and excise tax disputes. For multi-state businesses, we coordinate representation across all relevant tax authorities simultaneously to resolve disputes efficiently.
How long does an IRS audit typically take?
IRS audit duration varies significantly based on complexity. A correspondence audit (limited scope, conducted by mail) may resolve in a few months. An office audit can take 3 to 6 months. A field audit, where IRS agents examine records on-site, often takes 6 to 18 months or longer for complex businesses. Cannabis 280E audits, transfer pricing audits, and audits involving multiple tax years can extend longer. Proactive cooperation and complete documentation generally accelerate resolution.
What records does the IRS typically request in an audit?
The IRS typically requests bank statements, accounting records, invoices, receipts, contracts, prior tax returns, depreciation schedules, payroll records, and supporting documentation for deductions and credits claimed. For specific industries, additional records are requested: COGS allocation documentation for cannabis businesses, R&D credit substantiation for technology companies, and ownership records for pass-through entities. The more complete and organized your documentation, the smoother the audit process.
Facing an IRS Inquiry or Tax Dispute?
GreenGrowth CPAs provides experienced tax controversy representation, from audit readiness through IRS representation, settlement negotiation, and expert witness services.
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