The Oklahoma Bar Journal May 2026

before the IRS” broadly. It includes communicating with the IRS on a taxpayer’s behalf, representing tax payers at conferences or hearings, preparing and submitting docu ments for them and even provid ing written federal tax advice. Once an attorney crosses into represen tation, they are no longer simply helping a client interpret correspon dence – they are operating within a regulated practice framework. Only certain individuals are authorized to represent taxpayers before the IRS. Among those autho rized are attorneys in good stand ing with the bar of the highest court of any U.S. state, provided they are not suspended or disbarred from practice before the IRS. The barrier to entry, however, is lower than many attorneys expect. No formal tax training is required to begin representing taxpayers before the IRS. That said, the responsibil ity for accurate advice and proper representation rests entirely with the practitioner. Attorneys interested in developing competency in this area may find the IRS Volunteer Income Tax Assistance (VITA) program to be a valuable way to gain practical experience and exposure to IRS processes. Effective representation also requires familiarity with IRS systems and procedures, includ ing obtaining a “Centralized Authorization File” (CAF) number, setting up a Tax Pro Account and “Secure Object Repository” (SOR), accessing the “Transcript Delivery Service” (TDS) and, for those seek ing to litigate, receiving admission to practice before the U.S. Tax Court. While establishing a tax resolu tion practice requires an investment of time and learning, attorneys who take these steps can provide mean ingful value to clients navigating IRS disputes and compliance issues.

Comes from a revenue officer rather than a centralized IRS unit Requests detailed financial statements, asset disclosures or business records Raises concerns about exposure beyond the spe cific tax year at issue These requests often mark a transition from administrative pro cessing to active enforcement, and early, strategic handling can sig nificantly affect the outcome. CONCLUSION IRS correspondence is rarely the beginning of a crisis, but it is almost always the beginning of a deadline. For attorneys, the value lies not in mastering every aspect of federal tax procedure but in knowing how to triage a notice, recognize when a response is required and identify when an issue has crossed the line into one that should be handled by a tax professional. In many cases, the most effective assistance an attorney can provide is simply helping a client slow down, read the letter carefully and respond appropriately – or directing them to the right professional before pro cedural rights are lost. With a basic understanding of the most common IRS letters and the risks they present, attorneys can better protect their clients from unnecessary escalation, missed deadlines and avoidable expense.

WHEN THE IRS ASKS FOR DOCUMENTS: AUDIT AND REVENUE OFFICER REQUESTS In addition to formal IRS notices, attorneys and their clients may receive document requests from IRS examiners or revenue officers. These requests are often issued during audits or collection investigations and should be treated differently from routine correspondence. Audit-related document requests typically seek substantiation for items reported on a return and may be issued through formal “Information Document Requests” (Form 4564) or less formal written correspondence. Revenue officer requests, by contrast, usually arise in collection matters and focus on financial information, assets, income and the taxpayer’s ability to pay. Unlike many informational notices, document requests in audits or collection cases are inherently responsive and substantive. The scope of the response matters. Providing incomplete information may esca late the matter, while overproduc ing documents can unnecessarily expand the examination or expose additional issues. As a general rule: Audit document requests should be answered carefully, with responses limited to the specific items requested. Revenue officer requests

often implicate financial disclosure obligations and should not be handled casually or without under standing the downstream consequences.

ABOUT THE AUTHOR

A dedicated tax and business attorney, Ambrielle Glass focuses her practice in high-stakes tax disputes and corporate

Referral to a tax professional is strongly recommended when a document request:

structuring. With experience in both government and private practice, she brings a powerful combination of strategic insight and legal advocacy.

Is issued as part of an audit or examination

Statements or opinions expressed in the Oklahoma Bar Journal are those of the authors and do not necessarily reflect those of the Oklahoma Bar Association, its officers, Board of Governors, Board of Editors or staff.

MAY 2026 | 21

THE OKLAHOMA BAR JOURNAL