Clients hire me for “audit representation” all the time, and I’ve noticed most of them have only a rough idea of what that phrase actually means day to day. They know it means they won’t be sitting across from the auditor alone. Beyond that, the specifics are usually a blank.
That’s fair. From the outside, representation looks like one thing: someone else answers the phone. From the inside, it’s a lot more than that. So here’s what’s actually happening on a case while a client goes about running their business.
Before the First Document Ever Goes Out
Representation starts before the auditor gets a single piece of paper. The first thing I do on every case is go through the audit notice line by line — the tax types covered, the periods under review, the specific records requested — and compare that against what the business actually does.
This matters more than it sounds like it should. Notices are sometimes broader than they need to be, and requests occasionally reach into periods or transaction types that aren’t relevant to the issue that triggered the audit in the first place. Catching that early, before anything is produced, is a lot easier than trying to walk back an overly broad response six weeks in.
Managing What Actually Gets Sent
Every document request gets reviewed before it goes out the door. That doesn’t mean withholding anything the auditor is entitled to see — it means making sure what’s produced answers the specific request, instead of handing over an entire filing cabinet and hoping for the best.
A general ledger export that includes unrelated departments, a spreadsheet with formulas and notes never meant for outside eyes, an email thread with a stray comment about “how we usually handle it” — none of that is malicious, but all of it invites questions that have nothing to do with the actual audit. Part of the job is catching that before it leaves the building, not explaining it after the fact.
Being the Point of Contact for Every Question
Once representation is in place, the auditor’s questions come to me first. That single change shifts almost everything else about how the audit runs.
Questions get answered with a verified number pulled from the records — not a recollection, not an estimate, not whatever a busy owner remembers off the top of their head in the middle of a workday. If the answer requires checking a document, it waits until that document has actually been checked. That pause feels small, but it’s usually the difference between a precise answer and a guess that ends up carrying more weight in the file than it should.
Tracking Scope As the Audit Moves
Audits don’t always stay inside their original boundaries. A sales tax review can start looking at exemption certificates and quietly work its way toward use tax on fixed assets. A single quarter can start pulling in adjacent periods once something looks unusual.
Some of that expansion is legitimate — if the auditor finds something that genuinely warrants a closer look, that’s part of the process. But some of it happens simply because nobody was tracking what was being asked for and why. I keep a running log of every request against the original notice specifically so we notice the moment scope starts drifting, and can push back on it when it isn’t justified.
Reading the File the Way the Auditor’s Supervisor Will
Every audit eventually gets reviewed by someone who wasn’t in the room for any of the conversations — a supervisor, a review unit, sometimes an appeals officer well after the fact. That person only has the file. They don’t have context, tone, or the benefit of having met the business owner.
Having sat on that side of the process for years, I know what that review looks for and how conclusions get drawn from what’s written down. Part of representation is making sure the file, as it’s being built, actually reflects the business accurately — not a rushed or incomplete version of it that happened to get written down first.
Negotiating the Findings, Not Just Reacting to Them
By the time an audit reaches a proposed assessment, representation shifts again — from managing the process to negotiating the outcome. That can mean challenging a sample projection that doesn’t hold up, pushing back on an exemption disallowance where the documentation actually supports the exemption, or working through penalty abatement where the facts justify it.
None of this is about disputing everything reflexively. It’s about making sure every number in a final assessment is one the facts actually support, not one that survived simply because nobody pushed back on it in time.
What This Adds Up To
None of the pieces above are dramatic on their own. Most of representation is quiet, procedural, and unglamorous — reviewing a document before it goes out, waiting for a verified number instead of guessing, keeping a running log of requests. But added together across the length of an audit, that steady attention is usually what separates an assessment that reflects reality from one that reflects whatever got said or handed over first.
This post is part of an ongoing series on Florida Department of Revenue audits, drawing on my experience as a former auditor for the IRS, the Florida Department of Revenue, and Deloitte & Touche.
About the Author
Orlando Monteagudo is a former CPA and compliance auditor with more than three decades of experience at Deloitte & Touche, the Florida Department of Revenue, and the Internal Revenue Service, where he audited businesses ranging from small family-owned operations to large organizations and high-net-worth individuals. Today, he represents Florida business owners before the Florida Department of Revenue — guiding them through pre-audit readiness reviews, active sales/use and reemployment tax audits, and post-audit follow-up.
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