IRS Appeals

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What is an IRS Appeal?

An IRS appeal is an essential process for individuals and businesses seeking to resolve disputes with the IRS when they believe the agency has made an incorrect determination regarding their taxes, penalties, or interest.

IRS Tax Appeal

5 Star Rated IRS Appeal Services from Our Tax Appeal Lawyers

This formal procedure allows taxpayers to challenge IRS decisions without the need for court involvement, offering a more efficient and cost-effective path to resolution. Common issues that may prompt an appeal include disputes over a Federal Tax Lien, Tax Levy, or the rejection of an Offer in Compromise, all of which can have significant financial consequences.

Get Professional Legal Help with Filing Appeals

• If the total amount of taxes, penalties, and interest is $25,000 or less, we file a small case request to start the IRS appeal procedure. For amounts over $25,000, we submit a formal written protest.

• With four decades of experience, we are your best ally from filing a protest to the IRS appeal conference and representation in federal courts, providing expert support at every stage.

• Get expert help in identifying the right IRS appeal process for your case, whether it’s filing a Collection Appeal Request for liens or levies, appealing an Offer in Compromise (OIC), or handling a Trust Fund Recovery Penalty (TFRP) appeal. With our five-star-rated service, we ensure every detail is perfectly in place, doubling your chances of acceptance.

• Our tax attorneys provide professional assistance with the accurate preparation of IRS Form 9423, ensuring that every detail is properly reviewed and completed for your Collection Appeals Request. Take action now to safeguard your financial future!

Our expert tax attorneys excel in resolving IRS appeals, securing the relief you deserve.

Eligibility Requirements to File an Appeal

• You have received a Notice of Deficiency from the IRS informing you of your right to appeal their decision.

• You disagree with the IRS’s decision and wish to contest it.

• You have chosen not to sign IRS form 870 (the agreement form) sent to you by the IRS.

• If all of the above are true, you may be ready to request an Appeals conference or hearing.

Factors to Consider Before Filing an IRS Appeal:

• If you believe the IRS has made an incorrect decision based on a misinterpretation of the law, review relevant IRS publications to strengthen your case. Be prepared to reference these materials during your appeal.

• If you think the IRS applied the law incorrectly due to a misunderstanding of the facts, gather clear documentation and evidence to clarify your position during the appeals process.

• If the IRS is taking inappropriate collection actions such as a Federal Tax Lien, Tax Levy, or if your Offer in Compromise was denied, be ready to explain why you disagree and present supporting evidence.

• If the decision was based on incorrect facts, you should have well-organized records and relevant documentation to support your case and provide corrections during your IRS appeal.

• For situations involving Tax Topic 151 notifications or offset actions, consider reviewing your options with a tax professional, as these issues can impact refund status and may warrant further action or appeal.

IRS Appeal requirements

Expert Guidance through the IRS Appeals Procedure

Assessment for IRS Appeal

Our tax appeal lawyer carefully assesses your situation to determine if an IRS appeal is the right course of action.

Free Tax Relief Consultation
Eligibility for tax debt relief

Streamlined Application Process

Our certified tax attorneys will assist with a small case request using IRS Form 12203 or a formal form of notice of appeal for larger disputes.

IRS Appeals Officer Negotiation

We present compelling arguments, negotiate reductions in penalties, and aim to resolve disputes without the need for litigation.

tax debt resolution

Professional Support & Compliance

We provide continuous legal support to ensure you remain in full compliance throughout the process.

Assessment for IRS Appeal

Our tax appeal lawyer carefully assesses your situation to determine if an IRS appeal is the right course of action.

Free Tax Relief Consultation
Eligibility for tax debt relief

Streamlined Application Process

Our expert tax attorneys will assist with a small case request using IRS Form 12203 or a formal form of notice of appeal for larger disputes.

IRS Appeals Officer Negotiation

We present compelling arguments, negotiate reductions in penalties, and aim to resolve disputes without the need for litigation.

IRS form submission & debt negotiation
tax debt resolution

Professional Support & Compliance

We provide continuous legal support to ensure you remain in full compliance throughout the process.

tax attorneys specializing in tax debt relief

We offer expert relief to help you stop garnishments and reclaim your financial stability.

Why Do You Need a Professional Tax Appeal Lawyer?

Each year, the IRS issues millions of penalties and takes enforcement actions that burden individuals and businesses. In 2023 alone, the IRS processed over 271 million tax returns, collecting around $4.7 trillion to support federal operations

However, many taxpayers encounter unexpected issues, such as tax audits, IRS penalties, and tax liens, leading to stress and financial strain. These situations are often overwhelming, especially without expert guidance, making professional assistance essential for navigating the appeals process effectively.

“Our tax attorneys at J. David Tax Law specialize in helping clients fight back against these IRS actions.”

With years of experience and a deep understanding of IRS procedures, we work to minimize penalties, negotiate favorable outcomes, and ensure compliance throughout the process.

No matter what tax-related case you are facing, Our tax appeal lawyers can take the lead so you can focus on rebuilding your financial stability and give you the opportunity for a fresh financial start.

Choosing the Best IRS Appeal Option for You

When it comes to IRS appeals, selecting the right option can be critical to your success. Our tax attorneys are committed to helping you understand which appeal route fits your situation best. With every step tailored to your needs, we provide the guidance necessary to navigate complex IRS procedures efficiently.

A Small Case Request

If the total amount in dispute is less than $25,000, our tax attorneys can file a Small Case Request on your behalf. This simplified process avoids the formalities of a full appeal
while still giving you the opportunity to challenge an IRS decision. We ensure all supporting documents are submitted accurately to strengthen your case from the start.

Collection Appeals Program (CAP)

Our IRS appeal attorneys help clients utilize the Collection Appeals Program (CAP) to contest collection actions such as liens or levies.
This option offers a faster appeal process, and we make sure to advocate vigorously on your behalf, protecting your assets while seeking favorable terms. With CAP, we can also intervene before IRS actions escalate further.

Collection Due Process (CDP)

If you have received a Notice of Intent to Levy or a lien has been filed against you, our attorneys can guide you through the Collection Due Process (CDP) appeal.
We handle the submission of requests to ensure your right to a hearing, providing an opportunity to dispute the IRS’s actions or negotiate alternative resolutions.

Appealing Rejected Offer in Compromise (OIC)

Rejections are not the end of the road. If your Offer in Compromise has been denied, our tax attorneys step in to re-evaluate your financial
situation and present a compelling appeal. We understand the intricacies of the OIC process and are ready to negotiate with the IRS for a reconsideration that aligns with your financial reality.

Trust Fund Recovery Penalty (TFRP) Appeals

When the IRS holds individuals personally liable for unpaid payroll taxes, we help by filing Trust Fund Recovery Penalty (TFRP) appeals.
Our tax attorneys work to reduce or eliminate these penalties, ensuring that only those responsible are held accountable.

Innocent Spouse Appeals

For clients unfairly burdened by a spouse’s tax liability, we assist in filing Innocent Spouse Appeals. Our tax attorneys gather the necessary evidence to demonstrate
your eligibility, ensuring the IRS considers your claim fairly. We handle the entire process to help you achieve financial relief and peace of mind.
Frequently Asked Questions

Your Tax Relief Questions, Answered

IRS Form 9423, also known as the Collection Appeals Request, is used when you disagree with IRS collection actions, such as levies, liens, or property seizures. Filing this form allows you to request a hearing to appeal these actions before they take effect.

A Notice of Appeal is a formal document that initiates an appeal of an IRS decision, such as an audit result or tax deficiency determination. It signals your intent to challenge the IRS’s findings in either administrative appeals or court proceedings. Our tax attorney will file this notice within specific deadlines to be valid and ensure immediate resolution.

If your IRS appeal is refused, you may proceed by filing a petition in federal court, such as U.S. Tax Court, to dispute the IRS decision. This bypasses the IRS Appeals Process, allowing a judge to review your case. Tax attorneys can ensure compliance with filing requirements and deadlines, making your argument effectively in court. If you choose not to bypass, there may still be opportunities for re-evaluation, especially if new evidence arises.

IRS audit lawyers provide legal support throughout the audit process by representing taxpayers, ensuring compliance with IRS regulations, and negotiating with the IRS on their behalf. You can contact J. David Tax Law IRS audit lawyers to identify discrepancies and guide you through appeals or dispute processes if the audit outcome is unfavorable.

If your IRS appeal is refused, you may proceed by filing a petition in federal court, such as U.S. Tax Court, to dispute the IRS decision. This bypasses the IRS Appeals Process, allowing a judge to review your case. Tax attorneys can ensure compliance with filing requirements and deadlines, making your argument effectively in court. If you choose not to bypass, there may still be opportunities for re-evaluation, especially if new evidence arises. Appealing an IRS decision means formally requesting a review of the agency’s action or determination, such as a tax deficiency or penalty. The appeal can be handled administratively through the IRS Office of Appeals or, if necessary, through the U.S. Tax Court or other federal courts.
If your IRS appeal is refused, you may proceed by filing a petition in federal court, such as U.S. Tax Court, to dispute the IRS decision. This bypasses the IRS Appeals Process, allowing a judge to review your case. Tax attorneys can ensure compliance with filing requirements and deadlines, making your argument effectively in court. If you choose not to bypass, there may still be opportunities for re-evaluation, especially if new evidence arises. The IRS dispute form is typically IRS Form 12203, used to file a small case request to appeal an IRS decision involving disputes under $25,000. This form allows taxpayers to contest the IRS’s determinations without needing to go through a more formal appeals process.
If your IRS appeal is refused, you may proceed by filing a petition in federal court, such as U.S. Tax Court, to dispute the IRS decision. This bypasses the IRS Appeals Process, allowing a judge to review your case. Tax attorneys can ensure compliance with filing requirements and deadlines, making your argument effectively in court. If you choose not to bypass, there may still be opportunities for re-evaluation, especially if new evidence arises. A Notice of Deficiency, often called a “90-day letter,” notifies you of the IRS’s intent to assess additional tax after an audit. You have 90 days to either pay the amount due or file a petition with the U.S. Tax Court to challenge the assessment. Ignoring the notice can lead to enforced collection actions by the IRS.

If your IRS appeal is refused, you may proceed by filing a petition in federal court, such as U.S. Tax Court, to dispute the IRS decision. This bypasses the IRS Appeals Process, allowing a judge to review your case. Tax attorneys can ensure compliance with filing requirements and deadlines, making your argument effectively in court. If you choose not to bypass, there may still be opportunities for re-evaluation, especially if new evidence arises.

For more, you can visit our page JDavidTaxLaw.com or contact us at (888) 789-5011 to talk with our tax lawyers and discuss the best course of action toward resolution. If you need a more comprehensive breakdown of these options, feel free to check out our “Different Options for IRS Appeals and Their Meanings” guide

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