IRS Appeals

In the event that the outcome of your case is less than what you believe is fair and equitable, you have the right to appeal the IRS's decision. The IRS has a special department devoted to appeals called The IRS Appeals Division. The objective of the IRS Appeals Division is to resolve disputes between taxpayers and the IRS.

The rules governing the appeals process are precise and must be adhered to exactly. For this reason, you should engage the services of Tax Network USA to ensure that none of the appeals deadlines are missed and that all of the proper paperwork is filed accurately.

The appeal is your chance to re-state your case and to explain why you should be given another evaluation. Our Tax Professionals are highly knowledgeable about the appeals process and are trained to provide you with all the necessary support you will need.

Appeals of IRS Collection

If you disagree with the findings of an audit examination, you may request a meeting with the employee's supervisor. If you still do not reach an agreement, the IRS should provide you with a report and/or letter that explains the proposed adjustments and informs you of your right to request a conference with an appeals officer. The appeal must be supported by factual and legal argument.

All collection actions may be appealed. Never delay an appeal. If possible, try to get the appeal sent out within two weeks. Very often you will forfeit your right to an administrative appeal if the appeal is not timely. Among the determinations that can be appealed are: penalties; the trust fund recovery penalty; offers in compromise; employment tax adjustments; liens; levies; seizures; abatement of interest; determinations of fraud; and other claims.

You should be represented by Tax Network USA on any appeal for several reasons:

• An experienced tax professional will have more credibility than yourself, an enrolled agent and accountants (including CPAs). Tax law is "law" and those who aren't experienced in this arena, such as yourself, aren't trained to find all of the tax law and understand how to creatively interpret it without tax law experience and training.
• Like it or not, appeals officers can't be relied upon to give your case fair and balanced professional consideration. They often assume the role of IRS advocates.
• All appeals should be made in writing under penalties of perjury. It is very critical that substantial factual and legal argument be made in the appeal protest. When your tax advisor makes that argument, the IRS appeals officer will read it, and it becomes part of the administrative record for his manager and for litigation, if necessary. Since a tax advisor will cite technical authority, it's much easier for the appeals officer to digest the legal memorandum and study it prior to the conference. In contr
• Their is no downside in doing an appeal. Collection and examination determinations are usually aggressive. The appeals officer's job is to settle cases and keep them out of the Tax Court - they can factor the risk of loss to the government in the case of liquidation. Further, you are required to pursue all administrative remedies in the event you choose to sue the IRS for negligence.

You Have the Right to Tax Representation

If you have been contacted by the IRS or your state's Department of Taxation, or have received tax liens, levies or notices of IRS intention to do so, contact us at 888-466-4706 or fill out our online form without delay to discuss the details of your specific tax situation.