Almost every audit I represented while at the Florida Department of Revenue started the same way. I’d call the business owner, introduce myself, and ask a few routine opening questions. And almost every time, the owner answered every single one of them — fully, cooperatively, sometimes eagerly — without asking who I was on the phone for, what the answers would be used for, or whether they should get someone in their corner first.
I don’t say that to criticize those owners. Most people believe that being open and cooperative is the safest way to handle an audit. It feels honest. It feels efficient. And for a long time, I let owners believe that answering quickly was helping their case, because from where I was sitting, it usually was helping mine.
Now that I sit on the other side of the table, I tell every client the same thing on day one: don’t talk to the auditor directly. Not because you have something to hide. Because you don’t know what you don’t know, and the auditor absolutely does.
An Audit Isn’t a Conversation — It’s a File Being Built
This is the part most business owners never fully grasp, and it’s the single biggest reason representation matters. An FDOR audit isn’t a back-and-forth discussion between you and the person sitting across from you. It’s a record being assembled for someone who will never meet you — a supervisor, a review unit, sometimes an appeals officer years later — who will read the file long after the conversation is forgotten.
Every answer you give becomes part of that file. Every offhand comment, every guess, every “I think we probably” or “usually we just” gets written down as if it were a precise, verified statement of fact. An auditor isn’t being dishonest by doing this — that’s simply how the documentation works. But a casual estimate from a nervous business owner can end up carrying the same weight in the file as a number pulled straight from the ledger.
I’ve watched a single loosely worded answer expand the scope of an audit by a full tax period. I’ve seen an owner’s guess about “most of our out-of-state customers” get treated as an admission covering every transaction of that type, going back to the start of the audit window. None of that happened because the owner lied. It happened because nobody was in the room to slow the conversation down and make sure the record reflected what was actually true, not what came out under pressure.
Cooperation and Direct Access Are Not the Same Thing
Business owners often equate “being cooperative” with “answering every question the moment it’s asked.” Those aren’t the same thing, and confusing them almost never works in your favor.
Cooperation means producing the records the auditor is entitled to see, responding to requests in a reasonable timeframe, and being straightforward about what you have and don’t have. It does not require putting an untrained, unrepresented business owner directly across the table from someone whose job is to build a defensible file of findings.
A representative doesn’t slow down a legitimate audit. What changes is who answers the questions, how those answers get framed, and how much gets volunteered beyond what was actually asked. That distinction — answering precisely versus answering completely — is where a lot of unnecessary exposure gets created.
What Actually Changes When You Have Representation
A few specific things shift once someone is managing the communication on your behalf.
- Questions get answered with verified information, not memory or estimation. If the answer requires pulling a document first, it waits until that document is pulled.
- Document requests get reviewed before anything goes out, so the auditor receives what was actually asked for — not an entire folder that invites new questions about unrelated transactions.
- Scope gets watched closely. An audit that starts as a sales tax review of one location can quietly expand if nobody is tracking what’s being asked and why.
- Nothing gets said that could be read later, out of context, as an admission covering more ground than the owner actually meant.
None of this is about obstruction. I know from years on the other side exactly which requests are standard procedure and which ones are an auditor testing how far the file can be pushed. Managing that difference is most of what representation actually does day to day — it’s rarely dramatic, and it’s almost never about hiding anything. It’s about precision.
The Owners Who Get Hurt Aren’t the Ones Doing Anything Wrong
This is the part that surprised me least as an auditor and bothers me most as a representative. The businesses that end up with the largest, most avoidable assessments are rarely the ones running a sloppy operation. They’re usually decent operators who simply answered too fast, guessed when they should have checked, or tried to be so helpful that they handed over more than the audit actually called for.
An audit is not a conversation you can talk your way out of, and it’s not one you should try to talk your way through, either. The goal was never to make the auditor’s job harder. It was to make sure that what ends up in the file is accurate, complete, and nothing more than what the facts actually support.
If you receive a notice — or even a phone call — from the Florida Department of Revenue, the single most useful thing you can do before saying anything substantive is get someone who has sat on the auditor’s side of that file into the conversation 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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