Frank Agostino published the July 2026 edition of the Taxpayer Assistance Corporation’s Journal of Tax Controversy, featuring “Everyone Has a Job to Do — Part 1 The Demand Ladder and the Privileges That Answer It.”
In the first of a series of articles for the Journal of Tax Controversy, Frank provides a breakdown of the demand ladder--the sequence of access and document requests by the IRS-- in IRS civil examinations with recommendations for practitioner responses in each stage of the examination process. He provides comprehensive guidance on the statutory nuances of each step of civil examinations and how practitioners can advocate for their clients.
The next issue of the Journal of Tax Controversy containing Part 2 of this series, Frank will discuss the "seven chairs at the examination table:" each actor at the table and their money and ethical codes, the professionals' conflicts, when a complaint is a letter or a lawsuit, and who ultimately pays at the conclusion of the examination.
You can view Part 1 here.
About Frank
During his four decades of practicing tax law, Frank has been the driving force behind many successful lawsuits that sought to establish fair tax enforcement principles for taxpayers. Frank has extensive courtroom experience, litigating more than 100 tax matters, several of which established important precedents for taxpayers.
