The IRS, perhaps not surprisingly, took a slightly different view. "Similar to paper records, it is important an exact copy of the original electronic data file be provided to the examiner and not an altered version," , Only an exact copy of the original file allows examiners to "properly consider the integrity and veracity of the electronic files."

Experts say it doesn't appear that the IRS is going outside its boundaries. "The IRS does have very broad powers in this area," says David Hammond, tax partner with BDO. Agents are authorized to examine any books, records or data that may be relevant to an audit, he adds, with a few exceptions. For instance, when examining a healthcare practice, the IRS cannot check patients' treatments.

Moreover, the concerns may not be all that relevant in practice, Hammond adds. "Usually people turn over everything. They want the audit to go well." Still, Hammond says he understands why people want to limit audit scope.

At this point, the situation appears to be in flux. According to conversations Goldstein has had, some revenue agents have received copies of both the AICPA letter and the IRS response, and shown them to taxpayers, as well. Goldstein surmises that the IRS is relying on the letters to provide uniform guidance to the agents. The IRS' letter explains its need for the software files, and offers assurance that the Service won't mishandle any information it receives.