The goal of the IRS Appeal Division is to “settle” disputes between the IRS and taxpayers.
The most common IRS decision which is appealed is that of an IRS Audit where the IRS has increased the taxpayer’s tax liability.Often this increase includes additional penalties and interest.The taxpayer must file an IRS Appeals request within a certain time frame and follow the IRS guidelines for an Appeal request to be valid.
An aggressive and knowledgeable Tax Attorney and/or Enrolled Agent can make a huge difference in the settlement you will be offered during the IRS appeals process. Like the taxpayers themselves, the IRS does not want to litigate these issues because of the time, expense, and risk of an unfavorable outcome. When the IRS loses a case, it sets a precedent that could cost them for years. A powerful professional on your side gives the IRS the maximum opportunity to lose. To avoid such a loss, the Appeals Officers usually look to settle these matters outside the courtroom altogether.
When an IRS audit ends up in an audit recommendation you do not agree with, Tax Group Center’s Tax Attorneys and/or Enrolled Agents can represent you before the IRS Appeals Office.
Appeals Officers are often more experienced than the Revenue Agents who handle IRS audits. The vast majority of disputed IRS tax audits are settled during the IRS appeals process. It is important to have someone who understands the procedure and has been there before. The IRS handles many appeals every year; you are only involved in one.
What is the process of an IRS Collection Appeal? There are a number of ways to halt IRS collections activities, including negotiating with the collections manager that is handling the case or seeking collection due process or collection appeal process hearing. Both the collection due process and the collection appeal process hearings involve expedited conferences with the IRS Collection Appeals Office to review decisions on liens, levies, seizures, and rejection or termination of installment agreements.
The key difference between these two programs is that the IRS collection appeals program does not allow further appeal to a court from denial of the appeal; whereas, collection due process does. An experienced professional can help you determine if you qualify for these programs.