Pre-Audit Investigations

Before a formal audit begins, the IRS may conduct a pre-audit investigation. These investigations can be triggered by information returns, third-party reports, or IRS data matching programs. How you respond at this stage can determine whether a full audit follows.

What Is a Pre-Audit Investigation?

A pre-audit investigation is an IRS inquiry that occurs before a formal audit is opened. The IRS may be gathering information, verifying reported amounts, or determining whether a full examination is warranted. These investigations may involve:

• IRS correspondence requesting documentation or clarification
• Information Document Requests (IDRs)
• Third-party summonses
• IRS Criminal Investigation Division (CID) inquiries

Why Early Representation Matters

What you say and provide during a pre-audit investigation can be used against you in a subsequent audit or criminal investigation. Having an attorney represent you from the earliest stage ensures:

• Attorney-client privilege — all communications are protected
• Proper responses — only required information is provided, nothing more
• Rights protection — your taxpayer rights are preserved throughout the process
• Strategic positioning — responses are crafted to minimize audit exposure

Criminal Investigation Division (CID) Contact

If the IRS Criminal Investigation Division contacts you, do not speak to them without an attorney present. Anything you say can be used against you in a criminal prosecution. Contact Philip Falco immediately for representation.

Call (303) 626-7000 immediately if you have been contacted by the IRS regarding a pre-audit investigation.