Tax Attorney for IRS Appeals
IRS Appeals is an independent function within the IRS that can overturn decisions made by examiners and collection officers.
When the IRS makes a decision you disagree with — an audit assessment, an OIC rejection, a lien filing — you generally have the right to appeal. IRS Appeals Officers have broad authority to settle cases based on the "hazards of litigation," meaning they consider what would happen if the case went to court.
A tax attorney brings legal arguments to the appeals process that change the dynamics. An Appeals Officer who might deny a taxpayer's protest will often negotiate with an attorney who can credibly threaten Tax Court litigation.
Collection Due Process
A CDP hearing is a special type of appeal triggered by certain lien and levy notices. It's your opportunity to challenge the proposed collection action and propose alternatives. If you disagree with the CDP result, you can petition the Tax Court — something only an attorney can effectively handle.
If the IRS has denied your request or you want to challenge a collection action, let's discuss your appeal options.
32 years of IRS experience. Free consultation. I will tell you exactly where you stand and what your options are.
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