How the IRS Uses Your Bank Records in an Audit or Investigation

Marc Boulanger • May 23, 2025
Two women are working in a server room with a monitor that says irs audit procedures on it.

Yes, the IRS Can Look at Your Bank Records


If you're being audited—or worse, under IRS investigation—expect your bank accounts to come under scrutiny. The IRS has the legal right to review your financial activity, and they know exactly what to look for.


The key is understanding when they look, what they’re trying to prove, and how to prepare or protect yourself if you’re under the microscope.


When Does the IRS Look at Bank Records?


The IRS typically examines bank records during:


  • Field or office audits
  • Audit reconsiderations
  • Collection investigations
  • Criminal tax investigations
  • Offer in Compromise reviews


In many cases, they will issue a Form 4564 (Information Document Request) asking you to submit 6–24 months of bank statements voluntarily. If you don’t comply, they can subpoena your bank directly under IRC §7609.

Related: What Happens After an IRS Audit Assessment?

What Is the IRS Looking For?


IRS examiners use your bank records to compare reported income to actual deposits. This technique is called the Bank Deposit Analysis method.


They’re looking for:


  • Unreported income
  • Structured transactions (to avoid $10K thresholds)
  • Personal vs. business expense commingling
  • Large cash deposits
  • Foreign wire transfers or account activity
  • Hidden income streams (Venmo, PayPal, Zelle, crypto wallet transfers)


For businesses, they may also look for improper deductions, undocumented expenses, and payroll inconsistencies.

Related: IRS Tax Transcripts – Why They Matter

What If They See Something Suspicious?


If the IRS finds discrepancies, they may:


  • Increase your audit scope
  • Disallow expenses or deductions
  • Assess accuracy-related penalties (20%)
  • Refer your case to IRS Criminal Investigation (CI) in extreme cases


Even small inconsistencies—if repeated—can create a pattern of negligence or fraud.

Related: How to Challenge IRS Penalties (Abatement and Appeals)

How to Protect Yourself


1. Maintain Clean Records


Separate business and personal funds. Use accounting software or spreadsheets to document income, transfers, and deductible expenses.


2. Get a Transcript and Compare


Use IRS transcripts and your own bank data to identify mismatches.

Related: Tax Transcripts – Why They Matter

3. Don’t Volunteer Extra Years


Only submit the years or records specifically requested. Over-disclosing can unintentionally expand the audit.


4. Work with a CPA, Not Alone


If the IRS is asking for your bank records, you need representation—especially if you're self-employed or have large cash flow.


We Help Orange County Taxpayers Navigate IRS Bank Record Audits


At Boulanger CPA and Consulting PC, we:


  • Handle all IRS information requests on your behalf
  • Analyze bank data before submitting to the IRS
  • Push back on overreach or vague demands
  • Build your case to avoid penalties and referrals


Call (657) 218-5700 or schedule a strategy call at www.orangecounty.cpa


Local. Experienced. On your side.


Frequently Asked Questions

  • Can the IRS see my bank account without my permission?

    Yes. If you don’t comply, the IRS can issue a summons to your bank directly.

  • What if I deposited personal money into a business account?

    You need to clearly explain those transactions and back them up with documentation.

  • Will the IRS see payments from Venmo or Zelle?

    Possibly. Especially if they request access to digital payment records or if those accounts are tied to audit activity.

  • Can I get in legal trouble from what they find?

    If the IRS believes you intentionally concealed income, yes—it may be referred to the criminal division.


📣 About the Author


Marc Boulanger, CPA is the founder of Boulanger CPA and Consulting PC, a boutique tax resolution firm based in Orange County, California and trusted by high-income individuals and business owners across Southern California.


With over a decade of experience resolving high-stakes IRS and State tax matters, Marc brings strategic insight to complex cases involving wage garnishments, bank levies, unfiled returns, and six-figure tax debts. He is known for helping clients reduce or eliminate tax liabilities through expertly negotiated settlements and compliance plans.


Marc is a Certified Public Accountant licensed in California and Oklahoma and holds the designation of Certified Tax Representation Consultant. He is a member of the American Society of Tax Problem Solvers (ASTPS) — the national organization founded by the educators and practitioners who have trained thousands of CPAs, EAs, and tax attorneys in IRS representation strategy.


Every case is handled with discretion, proven methodology, and direct CPA-led representation — not call center scripts.


📍 Learn more at www.orangecounty.cpa or call (657) 218-5700.


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