Can the IRS Really Do That? Third Party Contacts, Notification Duties, Reprisal Exception, and More.



Getting audited by the IRS is bad enough, but having the IRS tell friends, colleagues, employers, clients and others about it can be worse. Unfortunately, the IRS does this on a regular basis through a process called making third party contacts (“TPCs”). Taxpayers often lack knowledge about TPCs, mandatory warnings, exceptions to general notice requirements, opportunities to supply data to the IRS to prevent TPCs, and various legal procedures for retrieving details about TPCs. This article addresses these critical points.


About Hale E. Sheppard

HALE E. SHEPPARD, Esq. (B.S., M.A., J.D., LL.M., LL.M.T.) is a Shareholder in the Tax Controversy Section of Chamberlain Hrdlicka and Chair of the International Tax Group.

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