IRS Enforcement Activity Is Rising — and So Is Tax Controversy Caseloads
The IRS has been expanding its enforcement capacity following the Inflation Reduction Act funding increases. According to the IRS Data Book 2024, individual and business audit rates increased for the second consecutive year, with high-income individual and large partnership examinations showing the largest percentage increases. The IRS also reported a 19% year-over-year increase in collection notices issued in 2024.
For tax controversy attorneys, this enforcement uptick translates directly into higher caseloads — and a corresponding increase in the volume of IRS correspondence, document requests, and audit coordination activity that surrounds each engagement. Tax controversy matters are uniquely correspondence-intensive: every case involves cycles of information document requests (IDRs), agent correspondence, response preparation, and follow-up that generate administrative workload independent of the underlying legal analysis.
IRS Correspondence Tracking
A tax controversy VA maintains a correspondence log for every active matter, recording each IRS notice or letter by notice number, issue date, received date, response deadline, and assigned attorney. For matters with multiple correspondence threads — common in large examination cases involving separate issues or multiple tax years — the VA maintains issue-level correspondence tracking so the attorney has a complete view of outstanding items by case and by issue.
This tracking function is a risk management asset. IRS response deadlines are statutory in many contexts, and missed deadlines in examination or appeals matters can result in lost taxpayer rights. A VA maintaining a live deadline calendar with attorney alert reminders at defined intervals reduces the risk of administrative oversight that could harm the client's position.
Document Collection Coordination
IRS information document requests require organized, complete responses drawn from the client's books and records. A VA prepares document request checklists from IDR language, distributes requests to the client with instructions for organizing responsive materials, tracks incoming document submissions, reviews for completeness against the IDR items, and organizes the production set for attorney review before submission to the agent.
For business clients with complex records distributed across accounting systems, payroll platforms, and external advisors, a VA serves as the central coordinator ensuring all source data flows to the firm on time. According to a 2024 American Institute of CPAs tax practice management survey, document collection delays were cited as the leading cause of IDR response extensions in business examination matters.
Audit and Appeals Meeting Scheduling
IRS examination meetings, technical advisor conferences, and Appeals officer conferences require scheduling coordination between the attorney, the client, IRS examination agents or Appeals officers, and in some cases expert witnesses or accounting advisors. A VA handles meeting request correspondence, confirms availability across all parties, prepares calendar invitations, and maintains a pre-meeting preparation checklist ensuring the attorney has all required documents and response materials organized before each IRS contact.
Client Status Updates
Tax controversy matters often extend for one to three years or more — a timeline that generates client anxiety without consistent communication. A VA sends templated status update emails at defined intervals, communicates new IRS correspondence to the client promptly, and tracks outstanding client action items (document submissions, signed consents) with follow-up reminders. This structured communication workflow reduces incoming client inquiry calls and improves client satisfaction scores across long-running matters.
Tax controversy attorneys ready to improve case capacity and IRS correspondence management can find specialized legal VA services at Stealth Agents.
Sources
- Internal Revenue Service, IRS Data Book FY2024
- American Institute of CPAs, Tax Practice Management Survey 2024
- U.S. Tax Court, Annual Report and Statistics FY2024