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File an Appeal

Tax Problem Solver File an Appeal

Did your IRS audit “go South”?

Was the auditor not listening to your reasonable explanations?

Didn’t believe your evidence and testimony?

Then you might want to appeal to a higher authority.

File an Appeal

Tax Problem Solver File an Appeal

Did your IRS audit “go South”?

Was the auditor not listening to your reasonable explanations?

Didn’t believe your evidence and testimony?

Then you might want to appeal to a higher authority.

Understand, Auditors are Very “Black and White.”

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There’s no middle ground or “gray” area, or compromises. It either is or isn’t. The action of filing an appeal puts the IRS on notice that you don’t agree with them and are seeking a meeting with the Appeals Division to try to change the IRS’ decision. And if you aren’t successful there, you can then go to the U.S. Tax Court and have a federal tax judge hear and rule on your case.

The Appeals Division Settles Cases
Do you know what the Mission Statement for the Appeals Division is? To settle cases so they don’t have to go to trial. Think about that. Appeals’ purpose is to settle tax cases, based on the “hazards of litigation.” So Appeals lives in the world of “gray” – to make reasonable settlement offers, still based on your evidence and testimony and the law, but with a reasonable approach.

Why You Need a Tax Attorney
This is where a team of professional tax attorneys can really do the job right, because lawyers and attorneys are trained and skilled negotiators, experienced at putting together persuasive arguments, affidavits, and statements of the law to get your best shot at a reasonable settlement, if not outright victory. And, of course, our attorneys can continue on to try your case in front of the United States Tax Court, if the strength and economics of the case warrant it.

There Are a Number of Appeal Options Available
Choosing the best one can be a real challenge. The Taxpayer Bill of Rights is a cornerstone document that highlights the ten fundamental rights taxpayers have when dealing with the Internal Revenue Service. Included is the right to appeal an IRS decision in an independent forum.

That means you are entitled to a fair and impartial administrative appeal of most IRS decisions, including many penalties, and have the right to receive a written response regarding the Office of Appeals’ decision. In addition, you also generally have the right to take your case to court (depending on which type of hearing you elect).

How to know if you should appeal
To decide if you should appeal your tax dispute, the IRS suggests you consider the following:

  • If you believe the IRS made an incorrect decision based on a misinterpretation of the law, check the publications discussing your issue(s), or refer to Tax Topics.
  • If you believe the IRS did not properly apply the law due to a misunderstanding of the facts, be prepared to clarify and support your position.
  • If you believe the IRS is taking inappropriate collection action against you, or your offer in compromise was denied and you disagree with that decision, be prepared to clarify and support your position.
  • If you believe the facts used by the IRS are incorrect, then you should have organized records or other evidence you should have organized records .

Why you must be careful when filing an appeal
Some of these appeals may be helpful, depending on your situation. However, remember that even though the Office of Appeals is "independent" of the IRS, they are still IRS employees, bound by IRS rules. With that in mind, without extremely persuasive evidence, they are not inclined to overturn a fellow employee’s decision. So while filing an appeal is a tempting way to hold the IRS at bay, it can also make your situation even worse.

Many of these appeals extend all relevant statutes of limitation, possibly inflicting even more damage to your financial situation. But some appeals can be taken without extending the statute of limitations. Be careful! The bottom line is, you may be best served to put an experienced tax attorney on your team.

Don’t Ignore the IRS – Things Get Bad Quickly!


Can you represent yourself? Sure.
Should you? Probably not, and here’s why:
If you appeal within the IRS, you must include all defenses and further claims, with complete supporting evidence and legal authority. This will likely be a difficult task.

Filing an appeal is a complex matter that requires a clear and complete understanding of the options and the process itself. And there’s typically a lot of money at stake! With Larry Heinkel and the Tax Problem Solver team at your side, you benefit from his 35 plus years of experience in dealing with the IRS and the finer points of getting you the best outcome possible.

The Tax Problem Solver Team’s intimate knowledge of the tax code can help you decide whether an IRS tax appeal is a viable solution to your problem. Get a FREE consultation with the team at Tax Problem Solver to see if an appeal is right for you.

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You Should Do and Should Not Do?

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When the IRS is after you, you need to be informed. What you say to the IRS can be used against you.
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Larry Talks About How He and The Tax Problem Solver Team will Work with You to Create a Game Plan to Solve Your Tax Debt Situation Before It Gets Worse.

Unlike Our Competitors, We Employ Only Accomplished and Compassionate Tax Attorneys
and Tax Resolution Specialists, Who Work as a Team to Solve Your Problems.

LARRY HEINKEL, J.D. LL.M.
TAX & BANKRUPTCY ATTORNEY

APRIL SERRANO, E.A., CTRS
ENROLLED AGENT &
CERTIFIED TAX RESOLUTION SPECIALIST

PATRICIA O’DONNELL, J.D.
LEGAL ADVISOR

KENTON SANDS, J.D., LL.M.
TAX ATTORNEY
(OF COUNSEL THROUGH SANDS WHITE & SANDS, P.A.)

JOE MCDERMOTT, E.A.
FORMER IRS APPEALS OFFICER

Why You Should Choose the Tax Problem Solver Team!

  • Your case will be reviewed by an expert Tax Attorney and other tax professionals including Certified Public Accountants and Enrolled Agents – on-staff and in-house – at your disposal.
  • Being Tax Attorneys, we have all the available tools at our disposal for your best tax resolution outcome.
  • With over 38 years of experience, we know all the tax rules and internal procedures.
  • We provide personalized attention to the details of each case, representing our clients in all dealings with the IRS including responding to all IRS communications.
  • Even if you haven't filed your taxes for a number of years, we can help get you back on track in restoring your financial security.
  • In most cases, we are able to settle outstanding taxes, penalties, and accumulated interest for a fraction of the amount due.
  • You can trust in our safe & secure site – all your information is held in the strictest confidence and none is ever sold or shared with third parties.
  • We will always go above and beyond to make your tax resolution process easier.

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Are You Ready to Find Out What
You Should Do and Should Not Do?

Choose one of the 3 FREE contact methods that is easiest for you.

Schedule a Call with Us

Click the calendar button below to view our appointment calendar, and choose a day & time, and we’ll call you then.

We look forward to your free consult!

Call Us Now

Click the phone button below to either "click to call" or direct dial a number to speak with us right now.

We look forward to speaking with you!

9-Secrets You Need to Know

When the IRS is after you, you need to be informed. What you say to the IRS can be used against you.
Get My 9 Secrets email series now. I'll also add you to my newsletter.

Call Us Now!