Not every IRS audit ends in full agreement. Taxpayers have the right to challenge unresolved audit issues in the IRS Independent Office of Appeals. IRS Appeals is an independent administrative forum designed to resolve disputes fairly and impartially, without the need for time-consuming litigation. Preparing a persuasive Appeals submission can significantly affect the likelihood of achieving a favorable resolution. An experienced IRS Appeals lawyer can help challenge proposed adjustments and other audit issues.

Common Appeals Issues

Appeals can be available and appropriate when:

• An audit results in proposed adjustments
• Penalties are assessed
• Issues of fact, legal interpretation, or application of tax law exist
• Settlement opportunities exist

Appeals Defense Process & Strategy

• Consider engaging an experienced IRS tax appeals lawyer as soon as possible.
• Carefully evaluate relevant facts and circumstances, develop tax technical positions on the issues, and develop a challenge strategy.
• Prepare and file a written protest to request Appeals review within the deadline.
• Assignment, Review & Conference: an Appeals Officer is assigned, reviews the protest, and sets a conference (can be telephone, video, or in-person) to discuss with the taxpayer.
• Focus the review & challenge on:
  • Legal hazards of litigation
  • Strength of the taxpayer’s position
  • Administrative settlement opportunities

Contact an experienced IRS tax appeals attorney

Nick Eusanio

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