Anatomy of a No Records Audit - Details:
Numerous catastrophic events occur leaving taxpayers in a position of having no records. Even the most attentive taxpayer is susceptible to the effects of a flood, tornado, hurricane or worse. Unfortunately, the Internal Revenue Code and other case law references provide little to no guidance with respect to no record audit situations. This session provides the practitioner the proper legal and procedural tools, resources and references related to representing a taxpayer before the Examination Division when no client records are available to provide substantiation. This presentation will guide the practitioner, providing statutory law and case law modules, to establish a generic approach to the issues that are germane to a no records audit. A formal no records audit plan/program and work papers will be designed from legal and regulatory cites as a course project to solidify the understanding of the no records audit process.