Tax Services
Tax Audit Defense & IRS Appeals
Former IRS Appeals Officer (GS-13 & GS-14) with 20+ years of insider experience defending clients nationwide against IRS audits, examinations, and disputes.
Insider Knowledge from the Decision-Maker’s Chair
When the IRS sends an audit notice, your response strategy determines everything. I’m Brian K. Gilroy, a Florida Bar Board Certified Tax Attorney and former IRS Appeals Officer who spent 15+ years inside the IRS—first as a GS-13 Appeals Officer handling individual and small business cases, then as a GS-14 officer resolving complex corporate disputes, and finally as a Technical Guidance Coordinator advising Appeals Officers nationwide on the most complicated tax issues.
I know how IRS audits work because I was the decision-maker. This insider perspective allows me to anticipate government positions, identify weaknesses in IRS determinations, and build strategic defenses that maximize favorable outcomes for my clients.
From Simple to Complex—Complete Audit Coverage
Individual Tax Audits
- Missing income allegations (Form 1040)
- Disallowed tax credits (EITC, CTC, AOTC)
- Charitable contribution verification
- Deduction substantiation disputes
- Correspondence audits (Letter 566)
Business & Corporate
- C Corp, S Corp, partnership audits
- Business expense challenges
- Entity classification disputes
- Multi-million dollar examinations
- Small business compliance issues
Complex Tax Issues
- Conservation easement disputes
- Research & development credits
- Appraiser penalties (IRC §6695A)
- Valuation & transfer pricing
- Tax shelter investigations
IRS Appeals & Litigation
- Appeals conference representation
- Collection Due Process hearings
- 30-Day Letter (Letter 525) response
- 90-Day Letter (Letter 3219) defense
- U.S. Tax Court representation
Understanding IRS Letters & Notices
Quick, strategic responses often prevent escalation and costly assessments
CP2000 Notice — Proposed Income Changes
Computer-generated notice identifying mismatches between your return and third-party information (W-2s, 1099s, brokerage forms). Requires documented response within strict deadlines.
Letter 566 — Correspondence Audit Notification
Formal audit notice usually focusing on one or two specific issues. Requests documentation by mail or upload. Missing deadlines can result in proposed assessments without your input.
Letter 525 — 30-Day Letter
Proposes changes after examination. You have 30 days to agree, provide additional evidence, or request an Appeals conference. As a former Appeals Officer, I know exactly what persuades Appeals to settle.
Letter 3219 — Statutory Notice of Deficiency (90-Day Letter)
Legal notice starting the 90-day clock to petition U.S. Tax Court. Ignoring this letter results in assessment and collection enforcement. I’m admitted to U.S. Tax Court and can represent you at this critical stage.
Tax Preparation as Built-In Audit Protection
The best audit defense starts with prevention. Many IRS examinations begin because of avoidable errors—missing forms, inconsistent reporting, or poor documentation. When your return is prepared by someone who understands IRS enforcement procedures, you drastically reduce audit risk.
Every return I prepare is built to withstand IRS scrutiny:
- Legal positions documented and supported
- Red flags identified and resolved before filing
- Supporting evidence organized and ready
- Prepared as if it will be examined
And if an audit notice does arrive, I already know your return inside and out—allowing me to respond strategically from day one.
Prevention Is the Best Defense
Tax preparation clients receive built-in audit protection because their returns are prepared by someone who knows exactly how the IRS evaluates cases.
Why Former IRS Experience Matters
Strategic Advantage
I know how IRS Appeals Officers evaluate cases because I wrote thousands of determinations. This insider perspective lets me anticipate government positions and identify weaknesses before they become problems.
Technical Expertise
As Technical Guidance Coordinator, I advised Appeals Officers nationwide on conservation easements, research credits, and complex technical issues—insight that translates directly into better client outcomes.
Proven Results
Thousands of cases resolved at IRS Appeals without litigation. My approach is grounded in impartial analysis, deep technical knowledge, and efficient resolution that serves taxpayers.
Dual Credentials
Board Certified Tax Attorney + CPA + LL.M. in Taxation. This dual expertise ensures both legal and financial aspects are thoroughly analyzed in every defense strategy.
My IRS Career Path
GS-13 Appeals Officer (6 Years)
- Individual taxpayer disputes
- Small business examinations
- Penalty determinations
- Collection Due Process hearings
GS-14 Appeals Officer (5 Years)
- Complex S Corporation disputes
- Partnership examinations
- C Corporation cases
- Multi-million dollar settlements
Technical Guidance Coordinator (5-6 Years)
Advised Appeals Team Case Leaders nationwide on the most complicated taxpayer compliance issues. Developed policy guidance and resolved novel technical questions across all areas of tax law.
Received an IRS Letter? Act Now.
Get insider expertise and strategic audit defense. Schedule a confidential consultation today.