What To Do When You Do Not Agree with an IRS Determination
When the IRS issues a determination with which you do not agree, you may oftentimes appeal that determination through an administrative process involving the IRS Office of Appeals. The IRS Office of Appeals, which operates independently from the IRS unit that issued the determination, is tasked with reviewing and resolving the tax dispute in an impartial manner.
Many types of determinations may be appealed including, but not limited to, additional tax assessments, assessments of penalties and interest, innocent spouse request denials, offer-in-compromise denials, and collections actions, such as levies or a Notice of Federal Tax Lien.
The specifics of requesting the appeal vary depending on the nature of the determination. But, in all cases, it is critical to file the appeal by the deadline.
Once submitted, your appeal will be forwarded to an Appeals Officer, with whom you – or your tax attorney – will have an appeals conference (usually by telephone).
Prior to the appeals conference, you – or your tax attorney – should submit a protest letter to the Appeals Officer explaining the facts and legal argument of your claim, along with all the relevant substantiation.
We have a comprehensive understanding of tax law, relevant procedural issues, and experience in negotiating with the IRS. If you want help resolving your tax dispute, we would be happy to help - contact us today!