Steve Weafer wrote:

- quote -

IRS Publication 1 describes how you can ask IRS to merely
terminate an examination where there was a no-change in
either of the two previous years and issues in the current
year examination are the same. Section 7430 of the tax code
provides for reimbursement of legal fees where t/p prevails
against an IRS position in a notice of deficiency which is
found to be substantially unjustified. It generally covers
costs for litigation, and cannot reach back to costs for
representation during the examination or appeals phases.

Fred F.

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Steve Weafer wrote:

- quote -

No such ruling.

However, if you have been "no changed" on an issue, and one
of the 2 (or both) immediately subsequent years are selected
for the same issue, then there is an ADMINISTRATIVE
procedure to have that subsequent audit terminated (or if
other issues are present, to have the "no changed" issue
excluded). This is at the IRS's discretion but usually
granted.

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I have read where if you are audited more than once on the
same issue and receive no change letters both times, the
third time you are audited for the same issue you can force
the IRS to pay your representation fees. Can anyone tell me
where I can find that Rev Ruling?

Thanks

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