Negotiating with the IRS?  Examiner vs. Supervisor vs. IRS Agent

Negotiating with the IRS? Examiner vs. Supervisor vs. IRS Agent

Negotiating with the IRS? Examiner vs. Supervisor vs. IRS Agent

When the IRS comes calling (or knocking), you may get that pit at the bottom of your stomach. While most of the time, the contemplation of what will happen is far worse than what actually happens the fear is commonplace by many of our client.

But, not all IRS employees are the same.

Negotiating with the IRS? 

Getting a visit from two IRS special agents, or sitting across from an Attorney in an IRS Investigation, is a far cry from being audited by an IRS Examiner, or having your taxes reviewed by Revenue Agent.

Examiner vs. Supervisor vs. IRS Agent

For example, while an IRS Special Agent may be an attormey (and/or have a legal background), an IRS Examiner or Officer positions are entry-level positions. These IRS employees will generally not have any legal background — which usually results in a much less “scary” experience for the taxpayer (which is a good-thing for the taxpayer)

Let’s explore some of the more common positions in audit and/or investigation types of matters.

Contacted by an Examiner, Agent or Tax Law Specialist?

Your first introduction to the IRS may be a basic audit. The audit may be a “paper” or “correspondence” audit, or possibly an in-person or business audit.

This is typically the first stop on the IRS food-chain. The person reviewing your taxes is usually a recent graduate of 2 or 4-year university.

These positions do not require any tax or legal background. We have found many of these IRS staff members to be overall pleasant, and less adversarial (since they are not attorneys).

*They have a very limited scope in the service they perform.

How does the IRS describe these Entry-Level positions?

IRS Examiner


This position reviews tax returns for accuracy and completeness, reviews and codes tax returns for computer processing, resolves errors and corresponds with taxpayers to obtain any missing information”

Revenue Agent


“In the IRS’ Small Business and Self-Employed (SB/SE) division, you’ll conduct examinations of individuals and small businesses to determine federal tax liability.”

IRS Tax Law Specialist


“As a Specialist, you’ll leverage the latest in mini and micro computers, telecommunications and data management systems. You’ll be a proactive decision-maker working with customers, businesses and the legal and financial communities.


Communicating with a Manager, Supervisor or Appeals Officer?

Your next meeting or communication with the IRS may be someone a bit more senior, such as an appeals officer, supervisor or technical manager.

These positions are higher-up the IRS food-chain.

The person you are communicating with will generally have more power or leeway to resolve your issue:

How does the IRS describe these Mid-Level Positions?

IRS Management Role


“You will be responsible for assigning, directing, and reviewing the work of subordinate employees.


You will use your leadership skills and management techniques for planning, scheduling, and coordinating work operations, planning and carrying out the training and development of employees, evaluating employees’ work performance, and in performing all other related administrative functions”


Revenue Officer

The role of the Revenue Officer is to collect taxes that are delinquent and have not been paid to the IRS and to secure tax returns that are overdue from taxpayers.  


To fulfill this role, Revenue Officers:  Conduct face-to-face interviews with taxpayers (and/or their representatives) at the taxpayer’s place of business or residence or, on rare occasions, at the Revenue Officer’s office.


These interviews may be scheduled or unscheduled (cold calls), depending upon the case. This is done as part of the investigative process of collecting delinquent taxes and securing delinquent tax returns.


Appeals Officer


Independent by statute, staffed by highly trained professionals who provide mediation for any taxpayer contesting IRS compliance actions.


Appeals is the last opportunity for the IRS and a taxpayer to resolve disputes prior to litigation, and ensures that all taxpayers can receive an impartial review of their tax case.

As an IRS Appeals Officer, you’ll conduct Appeals conferences to settle cases in which taxpayers have appealed IRS determinations on their tax case or filed a petition


Advanced IRS Position Example: Special Agent

When clients contact us with more serious inquiries involving offshore and foreign tax matters, it is generally because they were contacted by an IRS Special Agent.

If you are contacted by a Special Agent, you should always retain counsel first, since the agent is assessing your criminal culpability.

How does the IRS describe a More Advanced Position?

IRS Special Agent

As financial investigators, CI Special Agents fill a unique niche in the federal law enforcement community.


Today’s sophisticated schemes to defraud the government demand the analytical ability of financial investigators to wade through complex paper and computerized financial records. Due to the increased use of automation for financial records, CI Special Agents are trained to recover computer evidence.


Along with their financial investigative skills, they use specialized forensic technology to recover financial data that may have been encrypted, password protected or hidden by other electronic means.

Do You Need an Attorney?

Generally, when a person is communicating with the IRS, they will benefit from having an Attorney. This is because it helps protect the attorney-client privilege.

And, since the matter involves both tax and legal issues, clients generally beneift from having a dually-licensed Attorney/Enrolled Agent, or Attormey/CPA.

Golding & Golding, A PLC

We specialize exclusively in IRS Offshore & Voluntary Disclosure.

We have successfully represented clients in more than 1,000 streamlined and voluntary offshore disclosure submissions nationwide and in over 70-different countries. We have represented thousands of individuals and businesses with international tax problems.

We are the “go-to” firm for other Attorneys, CPAs, Enrolled Agents, Accountants, and Financial Professionals across the globe.

Golding & Golding (Board Ceritfied Specialist in Tax Law)

Golding & Golding (Board Certified Specialist in Tax Law)

Interested in Filing under IRS Amnesty Procedures?

No matter where in the world you reside, our international tax team can get you IRS offshore compliant.

Golding & Golding specializes in offshore tax and reporting amnesty. Contact our firm today for assistance with getting compliant.