“The Appeals mission is to resolve tax controversies, without litigation, on a basis which is fair and impartial to both the Government and the taxpayer and in a manner that will enhance voluntary compliance and public confidence in the integrity and efficiency of the Service.” IRM § 18.104.22.168
Audits are stressful whether it is your first one or not. Each Revenue Agent has a different temperament, education, experience level, and vocabulary. It is important for a tax practitioner to "speak the language" of the Revenue Agent at the Examination level to achieve the best possible outcome given the positions taken on the return. However some audits are better suited to be presented to an Appeals Officer in a face to face hearing.
Each negotiation is different but the only constants are taxpayers trying to avoid penalties and hoping that their tax position is ultimately upheld. However, there are creative solutions that can be applied in certain circumstances that indirectly achieve a better benefit for the taxpayer. Each taxpayer is different, each audit is different, and past results absolutely do not guarantee future outcomes.
Our team has guided a variety of taxpayers in different industries around the country through IRS audits and favorably resolved the issues prior to litigation. But if litigation is necessary to challenge the IRS then we are ready to help you have your day in court.