IRS Tax Appeals
If you have received a notice that the IRS has proposed adjustments to your tax return for one year or multiple years, you have the right to appeal those proposed adjustments. The IRS has two main methods by which you can file an appeal. The first method is to file an administrative appeal. The second method is to appeal through Tax Court. You will need to decide which method is best for your particular circumstances. In appeals, you will be able to appeal both the underlying tax and any proposed penalties. A written protest letter requesting an appeal should outline all issues that are in dispute based on the facts and pertinent tax law.
There are specific deadlines for filing a tax appeal with the IRS that you must abide by and that will be outlined in the correspondence you receive from the IRS. The appeals group of the IRS acts as an appellate arm of the IRS and reviews the documentation that has been provided to the IRS from you during the audit or during the collection matter. Under AJAC, the IRS appeals officer can assign an auditor to review new documentation that you provide tot the IRS appeals group that wasn’t provided to the examination or collection division. To a certain extent, you are also allowed to provide additional information or documentation that will be helpful to your case. If you disagree with a lien, levy, seizure, or denial or termination of an installment agreement, you may also have appeal rights.
What is the Difference Between Exam (or an audit) and the IRS Office of Appeals?
The IRS Office of Appeals employs policies and procedures are designed to ensure its independence from examinations. Appeals’ stated role is to settle disputes in a fair and impartial manner that favors neither the government nor the taxpayer. You can attempt to resolve cases after IRS compliance functions (Accounts Management, Collection, and Examination) have made a determination with which the taxpayer disagrees. The IRS Office of Appeals does not perform compliance actions.
Contact an IRS Tax Appeals Attorney
The stated mission of Appeals is to be independent and neutral. However, make no mistake that IRS Appeals Officers represent the government’s position and will protect the best interests of the IRS. If you have received a final notice of an IRS action, contact a Utah tax attorney for a free consultation.Free Consultation