Most IRS examinations remain civil. Potential criminal exposure turns on evidence of a willful violation and affirmative acts, not merely a large adjustment. Contact from IRS Criminal Investigation should be handled through experienced criminal tax counsel.

The IRS generally has three years to assess additional tax, but the starting date, six-year substantial-omission rules, unfiled returns, false returns, extensions, amended returns, and special statutes can change the deadline.

Audit reconsideration asks the IRS to reevaluate an assessed examination adjustment, usually when information was not previously considered. An amended return changes a taxpayer-filed return and may function as a refund claim. Neither replaces a live appeal or Tax Court deadline.

Correspondence examinations are generally handled by mail, office examinations involve an IRS office interview, and field examinations are conducted by revenue agents and may cover broader business issues. Scope, records, communication, and appeal rights depend on the actual case.

Answers to common questions about estimated payments, incomplete books, S-corporation compensation, and IRS notices. Each answer depends on the taxpayer's actual facts and current federal rules.

The ERC claim period has ended, but pending claims, disallowances, refund suits, promoter issues, amended income-tax returns, and audits remain active. The applicable assessment period depends on the quarter and current law.

A trade or business generally must file Form 8300 within 15 days after receiving more than $10,000 in cash in one transaction or related transactions. Cash definitions, aggregation, customer statements, e-filing, records, and structuring rules matter.

Form 2848 authorizes an eligible representative to act before the IRS for specifically listed tax matters and periods. It does not create unlimited authority, permit routine return signing, or allow the representative to receive or negotiate a refund.

Reasonable cause is penalty-specific and fact-specific. A persuasive request explains the event, timeline, ordinary business care and prudence, direct connection to the failure, corrective action, compliance history, and supporting records.

The individual estimated-tax penalty is based on required installments during the year, not merely the balance due with the return. Current-year tax, prior-year tax, adjusted gross income, withholding timing, annualized income, exceptions, and waivers all matter.

A bookkeeping catch-up period should be based on unfiled or inaccurate returns, opening-balance reliability, audits, financing, sale requirements, and available records—not a universal 12-, 24-, or 36-month rule.

An unpaid amount is not automatically deductible. Section 166 generally requires a bona fide debt with tax basis, and business versus nonbusiness classification changes the character, timing, partial-worthlessness rules, and reporting.

The Section 41 research credit may apply outside traditional technology companies, but qualified activities, expenses, funding rights, documentation, and the separate domestic research-expensing rules must be analyzed carefully.

Qualified Small Business Stock issued after July 4, 2025 may qualify for tiered exclusions after three, four, or five years, with higher gross-asset and per-issuer limits than earlier stock.

The original Opportunity Zone regime generally requires deferred gain to be recognized no later than December 31, 2026. A revised permanent Opportunity Zone program begins for qualifying investments made under the new rules starting in 2027.

Section 1031 generally applies only to qualifying real property held for business or investment. The 45-day identification rule, 180-day completion rule, qualified intermediary, related-party rules, debt relief, cash boot, basis, and depreciation all matter.

A home office inside the dwelling generally does not require allocating gain away from the Section 121 exclusion, but depreciation allowed or allowable after May 6, 1997 remains taxable. Detached structures and nonqualified use require separate analysis.

IRC §280A(g) may exclude rent from a residence rented for fewer than 15 days during the year. A related business receives a deduction only when the payment is a genuine, ordinary, necessary, reasonable, and properly supported business expense.

When property is rented to a business in which the owner materially participates, net rental income may be recharacterized as nonpassive while a net loss generally remains passive. Grouping and disposition rules require separate analysis.

Selling depreciated business property can produce ordinary income under Section 1245, unrecaptured Section 1250 gain for individuals, Section 1231 gain or loss, and additional entity or installment-sale consequences. The original cost, adjusted basis, depreciation allowed or allowable, and sale allocation control.