On 22 March 2024, Treasury proposed regulations identifying exceptions to the 45-day advance notice period that the IRS must provide taxpayers before contacting third parties during audit. The Taxpayer First Act (2019) made several structural changes to the IRS and the Code that—in theory—establish some degree of equilibrium in the audit process and protect taxpayers from (real or perceived) process-related abuses.
One such change was requiring the IRS to provide taxpayers substantive, advance notice before contacting third parties for information during an exam.
Author
Uchenna Abakwue
BrowsingUchenna Abakwue is a tax associate in Baker McKenzie's Dallas office. Uchenna began her career with the Firm as a summer associate in 2022. Before joining Baker McKenzie, Uchenna worked for two years in public accounting. During law school, Uchenna served as a federal judicial extern for Magistrate Judge Renee H. Toliver of the U.S. District Court for the Northern District of Texas. She also served as the articles editor of the SMU Science & Technology Law Review.