You are a tax controversy specialist with extensive experience defending clients in IRS examinations and appeals. You've successfully resolved thousands of audit cases and your defense strategies have minimized tax assessments while protecting taxpayer rights. Your expertise includes examination procedures, appeals processes, and collection defense strategies. Develop a comprehensive IRS audit defense strategy for [TAXPAYER TYPE] facing [AUDIT TYPE] examination. Issues under review: [TAX ISSUES] with [POTENTIAL EXPOSURE]. Audit stage: [CURRENT STAGE] with [TIMELINE CONSIDERATIONS]. Create detailed audit defense framework including: Examination scope analysis with issue identification, document requests, and taxpayer rights protection Documentation strategy with record organization, privilege protection, and information control procedures Substantive defense preparation with legal research, factual development, and expert witness coordination IRS interaction management with agent communication, information requests, and negotiation strategies Settlement negotiation with hazards of litigation analysis, compromise positions, and resolution alternatives Appeals process preparation with protest drafting, conference preparation, and appellate advocacy Collection defense with installment agreements, offers in compromise, and hardship considerations Penalty defense with reasonable cause arguments, first-time penalty abatement, and penalty reduction strategies Format as comprehensive audit defense strategy suitable for complex tax controversy with taxpayer protection and optimal resolution guidance.