If we do not like what the IRS says, we APPEAL.
Here is the Appeal Office job description and mission:
“The Office of Appeals is an independent organization within the IRS that helps taxpayers resolve their tax disputes through an informal, administrative process. Our mission is to resolve tax controversies fairly and impartially, without litigation. Appeals reviews cases after the IRS has made its decision, offering an objective point of view on each appealed case.”
Who would you rather work with, Revenue Officers whose job is to collect money, Revenue Agents whose job is to audit and find mistakes on tax returns, or Appeals Officers whose job is to settle the case? I choose Appeals.
We always try to settle matters with the person assigned to the case, but we cannot always come to a resolution. Fortunately, the law allow us to appeal decisions we do not agree with.
There are many types of Appeals. The best is the Collection Due Process Hearing. This is a one stop shop where all matters can be resolved. If we cannot agree on an Offer in Compromise, maybe the taxpayer is a good candidate for an Installment Agreement or to be placed Currently Not Collectible. The Appeals Officer can also grant a Penalty Abatement.
Appeals have to be made timely. As such, it is important to know your rights and when and how Appeals can be used to settle even the most difficult case.
Steven Klitzner is a tax attorney based in Miami, Florida. He has been practicing tax law for over 40 years, and currently holds a 10.0 rating by Avvo. Mr. Klitzner is a charter member of the American Society of Tax Problem Solvers, and he was appointed to the IRS Service Advisory Council in 2021. When not fighting for his clients, Mr. Klitzner is frequently found lecturing around the country and being quoted in various publications and news outlets about IRS tax and debt resolution matters.