IRS Audit Notice? You Need Experienced Representation Before You Respond.
Receiving an IRS audit notice is unsettling — but how you respond in the first days can determine the outcome of the entire process. At Ventresca & Ventresca LLP, Ken Ventresca has represented individuals, families, and businesses in tax audits and before the United States Tax Court for over three decades. This is not a sideline service. It is one of the most consequential things we do.
What an IRS Audit Actually Means — and Why It Matters Who Represents You
An audit is the IRS's formal examination of your financial information to verify that your reported income, deductions, and credits are accurate. Some audits are resolved through a straightforward exchange of documents. Others escalate into contested proceedings where the IRS proposes significant additional tax liability, penalties, and interest. The difference between those outcomes often comes down to the quality of your representation.
Ken Ventresca has spent 34 years understanding how the IRS builds and pursues audit cases — and where those cases can be challenged, negotiated, or resolved in a client's favor. When you work with us, you are working directly with the attorney handling your matter, not a paralegal or junior associate managing your file at arm's length.
The Types of Audits We Handle
IRS audits take several forms, and each requires a different approach. We represent clients across the full range of audit proceedings:
- Correspondence audits: The most common type, conducted entirely by mail. The IRS requests documentation to support a specific item on your return. While these appear routine, responding incorrectly or incompletely can open the door to broader scrutiny.
- Office audits: Conducted at an IRS office, typically involving more complex issues than a correspondence audit. Preparation and representation at the meeting are critical.
- Field audits: The most extensive form of audit, conducted at your home, business, or your representative's office. Field audits often involve multiple years and multiple issues simultaneously.
- Tax Court representation: When an audit results in a proposed deficiency that you dispute and cannot resolve at the IRS Appeals level, the United States Tax Court is the forum for contesting it. Ken Ventresca has represented clients in Tax Court proceedings and understands the procedural and substantive demands of that forum.
How We Approach Audit Defense
Every audit defense engagement begins with a thorough review of the IRS notice, the return or returns at issue, and the underlying documentation. Before we respond to anything, we need to understand what the IRS is actually examining, what it is likely to find, and what the realistic range of outcomes looks like. That assessment shapes every decision that follows.
Reviewing the Notice and Assessing Exposure
Every audit defense engagement begins with a thorough review of the IRS notice, the return or returns at issue, and the underlying documentation. Before we respond to anything, we need to understand what the IRS is actually examining, what it is likely to find, and what the realistic range of outcomes looks like. That assessment shapes every decision that follows.
Building the Response
A strong audit response is not simply handing over documents. It involves organizing and presenting your records in a way that directly addresses the IRS's inquiry, anticipates follow-up questions, and limits the scope of further examination. We prepare and submit responses on your behalf, communicate directly with IRS personnel, and ensure that nothing is provided that expands the audit beyond its original focus.
Negotiating at the Appeals Level
If the IRS examiner proposes adjustments you disagree with, you have the right to appeal within the IRS before any Tax Court proceeding becomes necessary. The IRS Office of Appeals is an independent function within the agency, and cases resolved at this level often produce better outcomes than those that proceed further. We represent clients through the appeals process and negotiate on their behalf with the goal of reaching a fair resolution.
Tax Court Representation When Necessary
When appeals do not resolve the dispute, the United States Tax Court is the next step. Petitioning the Tax Court requires meeting strict deadlines — most critically, the 90-day window to file a petition after receiving a statutory notice of deficiency. Missing that deadline forfeits your right to contest the IRS's determination before paying the tax. Ken Ventresca has the litigation background to represent clients in Tax Court and understands what it takes to build a case that holds up under scrutiny.
Why Clients Trust Ken Ventresca with High-Stakes Tax Matters
Ken Ventresca's track record in audit defense and tax court representation is built on 34 years of practice. Clients come to us at every stage — some immediately after receiving an initial audit notice, others after a prior representative failed to resolve the matter, and some only after the IRS has already proposed a substantial deficiency. We take cases at any point in the process.
What distinguishes our approach is the combination of legal depth and direct client access. Ken handles audit defense matters personally. He knows the tax code, the procedural rules, and the pressure points in an IRS examination. And because we are a boutique practice, you are not navigating this process through layers of staff — you are working with the attorney who knows your case.
Tax Audit Defense as Part of a Complete Tax Practice
Audit defense does not exist in isolation. The same knowledge that makes Ken Ventresca effective in an audit proceeding informs the tax return preparation and estate tax planning work we do for clients every year. When we prepare your returns, we prepare them with an understanding of what the IRS looks for and how to document your position correctly from the start.
For clients with complex estates, business interests, or multi-state tax exposure, that integration matters. Our estate planning and taxation practice covers tax return preparation, complex estate planning, and powers of attorney alongside audit defense — so clients have a single legal home for their tax and planning needs rather than managing multiple advisors who may not be coordinating with each other.
Frequently Asked Questions About IRS Audit Defense
What should I do if I receive an IRS audit notice?
Do not ignore it and do not respond without counsel. The first step is to read the notice carefully to understand what the IRS is requesting and what deadline applies. Then contact a tax audit defense attorney before submitting anything. What you say — and what you provide — in the early stages of an audit can significantly affect how the examination unfolds.Can an attorney represent me in an IRS audit without me being present?
Yes. Once you authorize legal representation, your attorney can communicate directly with the IRS on your behalf, attend meetings, respond to requests, and negotiate outcomes without requiring your presence at every step. This is one of the primary advantages of having counsel — it removes you from direct contact with IRS personnel and ensures that every communication is managed strategically.What is the difference between an IRS audit and a Tax Court case?
An audit is the IRS's examination of your return. If the audit results in a proposed deficiency that you dispute and cannot resolve through the IRS's internal appeals process, you can petition the United States Tax Court to have an independent judge review the matter. Tax Court is a formal federal court proceeding with its own rules and deadlines. The most critical deadline is the 90-day window to file a petition after receiving a statutory notice of deficiency — missing it eliminates your right to contest the proposed tax before paying it.How far back can the IRS audit my tax returns?
The standard statute of limitations for an IRS audit is three years from the date the return was filed or due, whichever is later. However, if the IRS identifies a substantial understatement of income — generally defined as omitting more than 25 percent of gross income — the lookback period extends to six years. There is no statute of limitations in cases involving fraud or when no return was filed. An attorney can assess which limitations period applies to your situation.Does receiving an audit notice mean I did something wrong?
Not necessarily. The IRS selects returns for examination through a combination of automated scoring, random selection, and specific criteria that flag certain deductions, income levels, or business structures for review. Many audits result in no change to the return. That said, how the audit is handled determines the outcome — and even a return that was prepared correctly benefits from experienced representation to ensure the examination stays focused and resolves appropriately.
Our Process Makes It Simple
Here’s how we make estate planning in St. Louis approachable and efficient:

Practical Guidance, Not Pressure
Book a 15-minute call—we’ll discuss your needs and answer your questions.
2. Explore Your Options
We’ll explain wills vs. trusts and help you decide what works best for your life.
3. Draft and Review
Every document is carefully created and clearly explained.
4. Sign With Confidence
You leave knowing exactly what your plan covers and how it works.
Ready to Talk to an Attorney About Your Audit?
If you have received an IRS audit notice or are facing a proposed deficiency, time matters. Deadlines in the audit and appeals process are strict, and early representation consistently produces better outcomes than waiting. Contact Ventresca & Ventresca LLP to speak directly with Ken Ventresca about your situation. We serve clients in Wexford, Pittsburgh, and the surrounding region, and we are available for same-day consultations when the circumstances require it.
