The Appeals process of the IRS provides taxpayers with an independent, impartial review of their case after the IRS makes a determination on a collection or an audit. It is usually the taxpayer’s last opportunity to reach an agreement with the IRS before the case goes to court.
A taxpayer is protected by the Taxpayer’s Bill of Rights to challenge an IRS decision by pursuing an appeal. Simply because the IRS takes a position favorable to them does not make them right; hence, many tax disputes are resolved in favor of the taxpayer.
The Taxpayer Bills of Rights entitles taxpayers to a fair administration appeal of most IRS decisions. When the IRS is wrong in their conclusions, the Appeals process is usually the best course of action. At ProTax, it is our standard procedure to do a three-point case review, when an IRS determination is not in our client’s favor. Some of the questions we raise include:
In order to improve our chance of winning at Appeals, we will go the extra mile for our client. However, we have to make sure that at least one of the above questions is answered with a “yes”, and some of the ways to do so is by providing evidence to support our position.
However, since the Appeals is usually the last best option to raise objections to resolve a tax controversy, it is strongly recommended to hire a qualified tax resolution specialist.