IRS Tax Audits & Litigation
New York IRS Tax Attorneys with Decades of Experience Handling Audits and Litigation
Any time you face scrutiny from the Internal Revenue Service, it is important to make informed decisions based on professional guidance. Audits can be invasive, complex and time consuming, and they often lead to significant financial consequences. Many individual and corporate taxpayers ultimately challenge audit results at the IRS Independent Office of Appeals or in federal court. Taxpayers who want to understand how these matters fit within broader IRS procedures sometimes review our firm background first.
A New York IRS tax attorney at Thorn Law Group can help if you are facing an audit or litigation. Our attorneys have decades of experience protecting clients from unwarranted tax liability, interest and penalties. We communicate with the IRS on your behalf, and when necessary, we litigate cases in the U.S. Tax Court, U.S. District Court or U.S. Court of Federal Claims.
Matters We Handle
We handle all types of federal tax audits, appeals and litigation for clients in New York and internationally. If you need guidance for any of the following matters, we encourage you to speak with a New York IRS tax attorney at Thorn Law Group:
IRS Tax Audits
The IRS audits hundreds of thousands of returns each year. It examines returns that show indicators of tax evasion or fraud and has increased its focus on businesses and high income taxpayers. If you received an audit notice, you must respond carefully and be prepared for the full review process. Many individuals preparing for an audit also benefit from reviewing other IRS compliance insight to understand how evidence will be evaluated.
We help taxpayers navigate all types of audits, including:
- Individual Income Tax Audits
- Corporate, Partnership and LLC Audits
- Payroll Tax and Trust Fund Audits
- ACA Related Audits
- ERC Audits
- PPP Audits
The IRS conducts three types of audits. Each presents risks. If revenue agents uncover evidence of underreporting or other violations, they can impose liability for back taxes, interest and penalties. If evidence suggests willful conduct, the IRS can refer the matter to IRS Criminal Investigation for further review.
Correspondence Audits
Correspondence audits occur by mail and make up the majority of IRS audits. Taxpayers must provide requested information while avoiding unnecessary disclosures or acceptance of inaccurate liability determinations.
Office Audits
An office audit involves a meeting with revenue agents at an IRS office. Taxpayers must be fully prepared to answer questions accurately and avoid mistakes that could broaden the inquiry.
Field Audits
Field audits take place at a taxpayer’s home or place of business and are the most intrusive form of audit. Our attorneys help ensure that you are prepared throughout the process and that the audit remains within proper boundaries.
Going to the IRS Independent Office of Appeals
If you need to challenge an audit outcome, your first step may be to go to the IRS Independent Office of Appeals. This office is separate from IRS examination and collection functions and evaluates cases independently. Appeals require clear evidence that demonstrates flaws in the IRS’s conclusions. We advise and represent taxpayers through each stage of this process.
Going to the U.S. Tax Court
In some cases, the U.S. Tax Court is a more appropriate venue than the IRS Independent Office of Appeals. Taxpayers may challenge administrative decisions here if earlier efforts were not successful. Our attorneys have extensive experience with Tax Court litigation and work to secure favorable outcomes using every available strategy.
Tax Litigation in U.S. District Court or the U.S. Court of Federal Claims
Some disputes must be litigated in U.S. District Court or the U.S. Court of Federal Claims. We prepare cases for trial while exploring settlement options that align with each client’s goals. If necessary, we also handle appeals in the appropriate U.S. Circuit Court of Appeals.
New Audit and Enforcement Developments for 2025 and Beyond
IRS enforcement is expanding in 2025 due to increased federal funding and advanced data analytics. The IRS is using third party reporting, foreign financial data, digital currency platform disclosures and payroll records to detect discrepancies. High-income taxpayers, partnerships, corporate structures and businesses with ERC or PPP filings are receiving more attention. These developments increase the importance of organized documentation and strong legal representation during audits and litigation.
Speak with a New York IRS Tax Attorney at Thorn Law Group
If you want to learn more about our IRS Tax Audits and Litigation practice, we are ready to assist. To speak with an experienced New York IRS tax attorney at Thorn Law Group, call (914) 534-6004 or contact us confidentially online today.




