IRS audits and investigations
An IRS notice is rarely the whole story — it’s one step in a defined sequence that ends in a lien, a levy, or a garnishment if it’s ignored. At DeVore Law, PLLC, IRS matters are handled exclusively by Devin S. DeVore, who represents clients before the IRS at every stage, from a first notice through Tax Court.
Knowing where a case sits in the IRS’s process — and which part of the agency actually controls it — shapes what response actually works.
The IRS in Tennessee — What You Need to Know
IRS collection follows a defined notice sequence: a CP14 notice announces the initial balance due, followed by a series of CP501, CP503, and CP504 reminder notices over the following months, and finally a CP90 Final Notice of Intent to Levy. That final notice triggers a 30-day window to request a Collection Due Process hearing before the IRS can actually levy a bank account or wages.
Most accounts are handled by the IRS’s Automated Collection System — a phone- and notice-based unit, not an individual agent. Larger or more complex balances get assigned to a live Revenue Officer, who works the case in person and has more discretion, and more authority, than ACS. Which one is handling a case changes the entire strategy for responding.
Audits work on a separate track, and the type matters: a correspondence audit is handled entirely by mail and usually addresses a single issue, an office audit requires an in-person meeting at an IRS office, and a field audit sends an agent to a taxpayer’s home or business and typically covers much more ground. The same underlying tax year can carry very different stakes depending on which audit type applies.
Underlying all of this is the 10-year Collection Statute Expiration Date — the IRS generally has 10 years from assessment to collect, though requesting an installment agreement, an Offer in Compromise, or a CDP hearing pauses that clock rather than running it out.
How DeVore Law, PLLC Can Help
Responding to the wrong part of an IRS notice, or missing a deadline buried in the fine print, can escalate a manageable balance into a levy. Devin DeVore brings direct experience across ACS, Revenue Officer cases, and audits to every file.
The IRS Notice and Collection Timeline
The IRS’s collection process follows a defined sequence, though the interval between notices can vary.
Three Ways an IRS Case Gets Assigned
Automated Collection System (ACS)
The most common assignment for smaller or more routine balances, handled by phone and notice rather than an assigned individual agent.
Revenue Officer Assignment
Larger or more complex balances get assigned to a specific Revenue Officer, who works the case in person and holds broader discretion than ACS.
Examination or Audit Division
A separate track entirely, covering correspondence, office, and field audits, each with a different process and a different scope.
Common Areas of Focus
Responding to a CP Notice
Each CP notice number triggers a different deadline and a different available response, and treating them all the same risks missing the one that actually matters.
Requesting a CDP Hearing
Filing within the 30-day window after a CP90 notice preserves the right to an independent review before any levy action proceeds.
Providing Financial Disclosure
ACS and Revenue Officer cases both eventually require a financial disclosure, and what gets submitted shapes every resolution option available afterward.
Documenting Audit Positions
Whether an audit is by mail, in an office, or in the field, the underlying documentation supporting a tax position doesn’t change — only how much of it gets reviewed.
I build each response around the specific notice, deadline, and IRS unit actually involved, not a generic reply.
When You Disagree — Appeals and Tax Court
An unfavorable IRS decision isn’t necessarily final.
IRS Office of Appeals
An independent division within the IRS reviews disputed audit results and rejected collection alternatives before a case ever needs to go to court.
U.S. Tax Court
Unlike most courts, Tax Court allows a taxpayer to petition and litigate a dispute without first paying the disputed amount — a meaningful advantage for a taxpayer who can’t afford to pay first and argue later.
What to Expect — Responding to the IRS
While each case differs, responding to the IRS generally follows these stages:
01
Notice and Case Review
We identify exactly which notice was received, what deadline it triggers, and whether the case is with ACS, a Revenue Officer, or Examination.
02
Documentation and Disclosure
We prepare the financial disclosure or audit documentation the specific stage of the case requires.
03
Negotiation or Hearing Request
We negotiate directly with ACS or the Revenue Officer, or file a Collection Due Process hearing request where the deadline allows.
04
Resolution or Appeal
Where a resolution isn’t reached, I pursue IRS Appeals or a Tax Court petition as the facts support.
Why Work With Devin DeVore for Your IRS Matter
IRS representation at DeVore Law, PLLC is not delegated between attorneys. Devin DeVore personally handles every case, offering:
Direct access to your attorney
Direct experience representing clients before the IRS
Representation in state and federal court throughout East Tennessee
Active involvement in the Tennessee and Knoxville Bar Associations
Practical, deadline-first response strategy
His approach starts with identifying exactly which IRS unit and deadline apply, then builds the response around that reality rather than a generic reply to the notice.
Speak With a Knoxville IRS Attorney
If you’ve received an IRS notice, a lien, or a levy, Devin DeVore can identify exactly where your case stands and what response actually applies.
Contact DeVore Law, PLLC to schedule a consultation and discuss your case with an attorney who works directly with the IRS.