IRS Appeals Representation

Do you need to appeal an IRS audit or a collection decision?

The Appeals mission is to settle tax disagreements without having to go to Court and a formal trial. Appeals is here to assist you if you don't agree with a tax decision. The Office of Appeals is independent of any other IRS office and provides a venue where disagreements concerning the application of tax law can be resolved on a fair and impartial basis.

An excerpt from the IRS web site: "An Appeals or Settlement Officer will review the strengths and weaknesses of the issues in your case and give them a fresh look. Appeals conferences are conducted in an informal manner, by correspondence, telephone or in person. Most differences are settled in these appeals without expensive and time-consuming court trials. Appeals will consider any reason you have for disagreeing, except for moral, religious, political, constitutional, conscientious objection, or similar grounds. Our goal is to provide a forum for us to work together to resolve the tax dispute."

Here is what the IRS has to say about appeals:

The IRS has an appeals system for people who do not agree with the results of an examination of their tax returns or with other adjustments to their tax liability.

If your examination or other adjustment was conducted through a personal interview with an IRS employee, the employee will explain your appeal rights to you. If you disagree with the findings, you may request a meeting with the interviewer's supervisor. If you still do not reach an agreement, or if the examination or other adjustment was conducted through correspondence, the IRS will send you a report and/or letter that explains the proposed adjustments. The letter also tells you of your right to request a conference with an Appeals officer, as well as how to make your request for a conference. If you request an Appeals conference, be prepared to support your position.

In addition to examinations, many other things can be appealed. Among them are certain penalties, including the trust fund recovery penalty, offers–in–compromise, employment tax adjustments, liens, levies, seizures, denials or terminations of installment agreements, collection due process notices, denials of abatement of interest and other claims.

Appeals conferences are informal meetings. Your conference may be face-to-face, or by telephone, or by correspondence. You may represent yourself at an Appeals conference; or, if you want, you may have an attorney, a certified public accountant, or an individual enrolled to practice before the IRS represent you. If you do not reach agreement with the Appeals or Settlement Officer, or you do not wish to appeal within the IRS, you may appeal certain actions through the courts.

For further information on the appeals process and information on how to stop interest from accruing on any anticipated liability, refer to Publication 5 (PDF), Your Appeal Rights and How To Prepare A Protest If You Don't Agree, and Publication 556, Examination of Returns, Appeal Rights and Claims for Refund. Also, Publication 1660 (PDF), Collection Appeal Rights, discusses how you can appeal collection actions.

Unfiled Tax Returns:  If you haven’t filed a tax return for one year, two years or ten years, we can help.  If you lost your records, no problem we can obtain them from the IRS.  So file your unfiled tax returns today.

1. IRS Audit: Did you receive a love notice from the IRS that you are under an IRS audit for one year, two years, or multiple years.  Let us know, we can represent you and help you with your IRS audit.
2. IRS Collection Activities: If you have an IRS wage garnishment a levy on your bank account, in need to establish a monthly payment with the IRS on IRS debt, or if you need to reduce your debt by filling an offer in compromise, we can help you with your IRS problem.
3. IRS Appeals: If your IRS Audit didn't go the way you wanted it to, call us, we might be able to appeal the auditor's decision.
4. IRS Offer In Compromise: Let's settle your IRS debt for pennies on a dollar.
5. IRS Employee Audit: Also known as the 100% penalty against reposible individuals such as Corporate officers.