§ 8a.5. Determination of audit method.

 When the taxpayer does not have complete records or when the review of each transaction would be unduly burdensome on the Department to conduct an audit in a timely and efficient manner, the Department will determine whether to examine all of the records of a taxpayer for an entire audit period, employ a test audit method or utilize a combination of audit methods. In making this determination, the Department will consider the following factors:

   (1)  The type of tax under audit.

   (2)  The nature of the taxpayer’s business.

   (3)  The number of transactions in the population.

   (4)  The adequacy and availability of the taxpayer’s records.

   (5)  Whether the taxpayer’s business is cyclical or seasonal.

   (6)  Whether significant changes in the taxpayer’s business or activities occurred during the audit period, such as discontinuing or adding a line of business.

   (7)  Other relevant factors.

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