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New York · IRS, NYS DTF & NYC audits

IRS and New York audits, answered with the full picture.

From an IRS field exam to a New York State residency audit, our Manhattan advisors manage the examiner, the document requests and the deadlines, so your response is consistent at every level.

Forms & standards
Form 2848NYS Form POA-1Residency audit183-day testBCMS conciliationDivision of Tax Appeals

Serving New York, NY, New York State, New Jersey.

What we handle

Three tax authorities, one consistent response

New York taxpayers can be examined by the IRS, the New York State Department of Taxation and Finance, and the New York City Department of Finance. Each has its own forms, auditors and appeal routes, and an answer given to one is usually seen by the others.

We represent business owners, executives with multi-state income, and people who moved out of New York. For residency audits in particular, the outcome turns on records such as calendars, phone and card data, and leases, so we build that evidence before the auditor asks.

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  • IRS correspondence and field examsBusiness, S corporation, partnership and individual returns examined by the IRS.
  • New York residency auditsDomicile and statutory residency reviews for people who left New York or split time between states.
  • New York State and City income tax auditsNonresident income allocation, wage allocation and work-from-home day counts.
  • Sales and use tax auditsSampling, exemption certificates and responsible-person exposure for New York businesses.
  • IRS Appeals and NYS conciliationProtests to IRS Appeals and conciliation conferences with the NYS Bureau of Conciliation and Mediation Services.
  • Tax Court and Division of Tax Appeals supportCase preparation with your attorney; the U.S. Tax Court holds trial sessions in New York City.
  • Penalty reliefReasonable-cause and first-time abatement requests at federal and state level.
  • Pre-move planningDocumentation plans for clients leaving New York so a later residency audit is easier to defend.

Where we help

Situations we see most in New York

Residency

You moved to Florida, New Jersey or abroad

New York asks whether you really changed domicile, or kept a home and spent more than 183 days in the state.

Allocation

Income earned partly outside New York

Nonresident wage and business income allocation under audit.

Sales tax

A sales tax field audit

Sampling methods that can multiply a small error into a large assessment.

IRS

An IRS exam of your business

Gross receipts, deductions and owner compensation under review.

Our approach

How the engagement runs.

Review the notice

We confirm which agency, which years and every deadline.

Authorize us

Form 2848 for the IRS and Form POA-1 for New York State.

Assemble the evidence

Records, day counts and written positions prepared before the first meeting.

Resolve or appeal

Negotiate the audit result, or take it to Appeals or conciliation.

Questions

Frequently asked

If your question isn't here, call (703) 880-8412 and you'll reach a person.

What is a New York statutory resident?

Generally, someone who maintains a permanent place of abode in New York for substantially all of the year and spends more than 183 days in the state, even if domiciled elsewhere. Statutory residents are taxed on all of their income, so day counts and housing records are central to these audits.

I moved out of New York. Why am I being audited?

New York regularly reviews people who change residency, especially high earners. The state looks at your home, business ties, time spent, items you value and family location to decide whether your domicile really changed.

Can you represent me before New York State?

Yes. CPAs can represent taxpayers before the Department of Taxation and Finance with Form POA-1, including at conciliation conferences.

What happens if I disagree with a New York audit?

You can generally request a conciliation conference with the Bureau of Conciliation and Mediation Services or file a petition with the Division of Tax Appeals, within the deadline stated on the notice.

Does an IRS change affect my New York return?

Usually. Federal changes generally must be reported to New York, and New York receives IRS audit information. We plan both responses together.

Do you handle New York City audits too?

Yes. We coordinate New York City income and business tax matters with the State audit so the positions match.

Latest updates

IRS & federal tax

All IRS & federal tax updates
Nov 5, 2026IRS & federal tax

IRS releases 2027 inflation adjustments (Rev. Proc. 2026-35)

For 2027 the joint-return standard deduction rises to $33,200, the estate tax basic exclusion to $15,480,000, the annual gift exclusion to $20,000 and the Section 179 expensing limit to $2,640,000. Our advisors recommend revisiting year-end gifting and equipment purchase plans with these figures in mind.

Source: IRS (IR-2026-133)

Our guidance

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