Corporate Tax Audit Survival

Tax Executive, The, May-June, 2005 by Michael J. Murphy

Cliff next turns to the importance of Advocacy before the IRS. Credit is given to TEI, the American Institute of Certified Public Accountants, and the American Bar Association, as well as smaller associations. Cliff's comments about the Industry Director's Directive (IDD) provide a clearer explanation of this type of directive along with concrete examples of problem resolution. Cliff also discusses Advocacy before the Congress, an area to which he devoted considerable attention before joining LMSB. In these chapters, Cliff offers up his own practical ideas for advancing the legislative and regulatory needs of a corporation and its outside representatives.

The closing chapter of Cliff's book is entitled Charting the Future of LMSB. Cliff gives himself good marks in improving relations between industry and the IRS, as well as for the reduction of audit time on large corporate cases. Cliff presents LMSB and its employees in a positive light by reporting that the many initiatives introduced during his four-year stay with the IRS will continue to bear fruit.

Cliff Jernigan's documentation of his work as a senior industry adviser in the LMSB Division of the IRS is the first in-depth view of an outsider to one of the four new divisions of the IRS, as restructured. Cliff conveys a clear message that the large corporate community can benefit by making use of the LMSB initiatives that have evolved since the "start up" of LMSB.

Michael J. Murphy is a tax group consultant with Sutherland Asbill & Brennan LLP. He formerly served as Deputy Commissioner of Internal Revenue (1987-1992) and Executive Director of Tax Executives Institute (1992-2002).