A North Carolina physician facing an IRS audit which would reveal several years of substantially under-reported income and over-reported deductions was able to resolve the audit civilly without referral of the case to Criminal Investigations Special Agents. The taxpayer, acting through his counsel, achieved the result by electing to voluntarily disclose the issues to the Revenue Agent and making arrangements to pay the past due tax liabilities.
The taxpayer was represented by civil counsel working with Douglas E. Kingsbery of Tharrington Smith, L.L.P.