IRS Appeals

The Internal Revenue Service has an appeals system for taxpayers who do not agree with actions that are proposed or taken by the IRS relative to their tax liability. The IRS Appeals Office is separate from the IRS examination division and IRS Collections. The Appeals Office is the only level of administrative appeal within the IRS. Conferences with Appeals Office personnel may be held in person, by telephone, or via correspondence.

Among the many IRS actions that may be appealed are the following:

• Audit/examination results and/or other adjustments to a taxpayer’s tax liability
• Collection actions, including notice of federal tax lien filings, levies and levy notices, seizures, wage garnishments, installment agreement terminations, rejected offers in compromise, denials of innocent spouse relief
• Employment tax adjustments and the Trust Fund Recovery Penalty
• Penalties and interest

An IRS Appeals Officer or Settlement Officer will review the strengths and weaknesses of the issues in your case and give them a fresh look. Appeals will consider any just reason you have for disagreeing with the IRS on a particular item or issue, except where the disagreement revolves around moral, religious, political, constitutional, conscientious objection, or similar grounds.

Although a taxpayer’s right to appeal is guaranteed in many cases, the IRS imposes strict requirements as to when and how a taxpayer must exercise his or her appeal rights, depending on the matter that is being appealed.

Tax appeals need to be handled carefully and with diligence, and by someone who is familiar with the IRS appeals process and who understands your rights and how to deal with the IRS.  If you handle an IRS appeal or tax issue improperly or fail to involve legal counsel, you may find yourself in a situation where you are facing IRS collection, where you are deemed to have waived your rights, or that you cannot resolve without going to court.  Having an experienced tax attorney on your side throughout the IRS appeals process may make a significant difference in the outcome of your tax appeal and minimize any potentially negative consequences.

If you wish to dispute a tax-related matter involving the IRS, a tax attorney at the Politte Law Offices can help.  Our tax attorneys are experienced in handling tax controversy matters for clients, and can assist you in filing an IRS appeal regarding the decisions made after a tax audit or examination, in tax assessments and penalty assessments, in collection actions, and can even in the face of criminal tax charges.

Contact the Politte Law Offices to speak with a Denver tax attorney and schedule a consultation.