As a tax lawyer, I have represented business clients for over 30 years. In fact, in larger audits, the Revenue Agents expect a team from the business lead by the tax attorney with the help of the outside CPA firm and in-house controller or CFO. The problem with CPAs handling tax audits alone is they are typically not as trained or skilled in negotiations and the adversarial process.
I am a lawyer and CPA and was a senior tax manager at Deloitte and Touche before I came out of law school and was tax counsel for 2 public corporations so have a lot of experience in this area since 1982. The asker is not a large corporation so do not see the relevance in your comment?
I represent many small businesses and even individuals. Tax Lawyers have a much different education and perspective than CPAs. In fact, many of my NJ State and IRS audit clients are referrals from CPAs.
So based on your comment, CPA's are at least smart enough to know when to bring you in for the assist when it is beyond their skill and education. In all candor Ron, I am not sure what you are trying to prove here with this dialogue so suggest we move on as it is not really productive as far as I can tell and professionals can have differing views as seems to be the case here.