tax-prep-pre-file-audit-premortem
Tax Prep — Pre-File Audit Premortem
Industry front door for premortem. Adds domain triggers, example, packs only. Run the parent's Process; parent content unchanged. Not legal or tax advice. Verify positions against current IRC/IRS guidance.
Activate when: a return has aggressive/uncertain positions (large Schedule C losses, high meals/vehicle, hobby-vs-business, real-estate professional status, R&D/ERC-type credits, crypto); before releasing a complex return; client says "will this get me audited?" Do NOT activate when: simple W-2-only standard-deduction return; the question is a straight lookup.
Why this variant
The parent premortem runs the clock forward to a failure and works backward. Here the "failure" is a notice/exam disallowing a position + preparer penalty (§6694) or client interest & penalties. Assume the return was pulled — what got disallowed and why? Fix before filing.
Domain inputs → parent's Process
- Imagine an IRS/state exam letter 18 months out.
- List every position that could be disallowed; rate substantial-authority / reasonable-basis + disclosure need (Form 8275).
- For each: is contemporaneous substantiation in hand now? If not, the position is a future loss.
Worked example
Client claims 95% business use of one vehicle, no mileage log. → Premortem: exam disallows for lack of a contemporaneous log → back-tax + accuracy penalty. Mitigation now: reconstruct/obtain log or reduce the position + note it. Decide before e-file.