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IRS sets five-year limit for consecutive audits of same taxpayer by same agent

A new IRS policy limits examinations and surveys of the same taxpayer by the same IRS employee to five consecutive years from the date of assignment. The policy applies to examiners and specialists in the IRS’ Large and Mid-Size Business (LMSB) Division and the Tax-Exempt and Government Entities (TE/GE) Division.

Generally, an examiner or specialist may not examine or survey a tax return of a taxpayer for more than five consecutive years (60 months) from date of assignment. If the examination is in process at the five-consecutive year point, the examiner or specialist is allowed to complete the examination provided the current cycle or audit has less than 12 months remaining from the five-consecutive year point.

The policy also applies to LMSB and TE/GE team managers but does not apply to normally recurring responsibilities of specialty managers and international managers. An assignment of 25 days or less is not considered part of an examination.

IRS Policy Statement P-4-5, November 27, 2006

 
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