Here is what I say to my clients and their advisors.
My valuation opinion is independent and objective, as required by federal law and professional appraisal standards. I will support it with all of the facts and proper methodology that I can bring to bear. I will defend it to the death. I have been through many audits and am still alive: draw your own conclusion.
I cannot advocate for my client’s cause because of the legal and professional standards. Your accountant and / or attorney will be the client’s advocate.
I have no opinion on any non-valuation matter. I will rely on information furnished by you and your advisors without independent verification. I am not an attorney or accountant and am unqualified to address such matters.
There is no point in my attending an audit session unless it concerns my valuation assumptions (other than those in the previous paragraph), methods, or conclusions. I will be silent on all other matters.
If the IRS questions my assumptions, methods, or conclusions on grounds I can defend (i.e., not legal, tax or accounting matters), I will be happy to work with them in person or by any other directed means of communication. I will charge by the hour for this, as I cannot control the time required.
If the IRS wishes to negotiate a settlement, that is a matter for your advocate to address, not me. I will not negotiate against my independent, objective opinion. On the other hand, if the IRS raises legitimate questions as to my assumptions, methods, or conclusions, I will always discuss them and perhaps revise my opinion if their facts and logic are compelling. If they simply stake out an arbitrary position without proof that is contrary to mine, I have nothing to add to my opinion.