By getting too greedy the Feeb ended up with nothing. Had only one pizza maker been targeted the cost of defending would have been prohibitive, but when several could combine their cases, they could afford to prevail.
Why the stupid matter wasn’t solved with a letter to the IRS about pizza recipes (and copies of menus) is another issue. The IRS ought to have been charged with frivolous prosecution.
“The IRS ought to have been charged with frivolous prosecution.”
This is the norm. They take unreasonable positions and the punishment is that you must defend against them. The system is the punishment.
I have another IRS audit underway right now. I showed the agent all of the errors in her work and agreed to disagree on the unbased assumptions creating assessments. It is very much a system where they make accusations and you must prove them wrong. You are NOT innocent until proven guilty. My client is between a rock and a hard place!
I’ll admit, I do end up with the nightmare cases after other CPAs have screwed them up. These are not returns I have prepared. I’ve even filed amended returns after the audit case was closed and paid, just to have the audit reopened and get my clients their money back. As long as the statute of limitations has not expired they are still open game.
I’m trying desperately to retire and get out of this work, but feel sorry for these people and keep getting sucked back into it.