Full article at The New York Times
"In other words, I could return home from a vacation or a stay in the
hospital to find not only that I am being audited, but that my audit has already
been closed and sent to the notice of deficiency unit. At this point I will have
two choices: I can either pay the bill or file a petition with the tax court. And
while I am not likely to know what losing my appeals rights means, I will soon
find out that it is too late to hire an enrolled agent or accountant to help
defend me against the I.R.S"
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