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Matson’s Musings: The audit’s opening act

By Greg Matson on September 11, 2026
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At TEI’s 2026 Audits & Appeals Seminar earlier this week, I learned something astonishing. During a discussion of managing audits and controversies, the audience was asked how many participants typically meet with a state auditor at the outset of an audit. Very few hands went up. One audience member estimated that such meetings occur only about 10 percent of the time. I’m certain I involuntarily impersonated Vizzini from The Princess Bride at that point: Inconceivable! Thankfully, no one noticed.

States use many names for these sessions: “opening conference” or “opening meeting,” “entrance conference,” “initial interview,” “introductory meeting,” and even “pre-audit conference” (akin to “pre-boarding” at the airport). Whatever the label, a large majority of states address some form of initial audit conference in audit manuals, taxpayer-bill-of-rights materials, website FAQs, brochures, or published audit procedures. Initial conferences are also a standard feature of every MTC joint multistate audit. Their prevalence, at least in writing, reflects the important role they play at the beginning of the audit journey.

The initial conference is more than an administrative formality. It marks the point at which tax administration shifts from unilateral government action to an interactive process involving dialogue between the auditor and the taxpayer. By establishing expectations, defining procedures, and opening lines of communication at the outset, the conference can make the audit more efficient. The agency can explain what it is doing and why; the taxpayer can explain its business operations and ask questions about the process and timing. Just as important, both sides can establish credibility and professionalism before disagreements arise.

States should make an initial meeting a routine part of every audit, and taxpayers should insist on one. Skipping that conversation is not merely a missed opportunity; it makes it harder to establish the clarity, efficiency, and trust that both sides will value as the audit proceeds.

Photo of Greg Matson Greg Matson
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  • Posted in:
    Tax
  • Blog:
    SALT Shaker
  • Organization:
    Eversheds Sutherland LLP
  • Article: View Original Source

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