Appeals Officers are some of the most highly trained members of the IRS. Many were previously senior members of the Collections Division or have a background in the area they are assigned to. Appeals Officers usually have a better understanding of the Internal Revenue Code than most IRS employees and are skilled negotiators who sharpen their skills through the high volume of cases they are assigned to.
Appeals conferences seem straight forward, but there is a lot of timing and strategy involved in planning how best to present your appeal. The appeals process has multiple deadlines that must be met or you may risk losing your appeal rights. In addition, since you only get one chance to take your case to the Appeals Division, an experienced tax attorney can help you make the decision on when is the best time to transfer your case. Sometimes the threat of escalating your case to appeals can help you achieve more favorable results with a Revenue Officer or Revenue Agent. Furthermore, while your case is being transferred to Appeals, an attorney can help you file a Freedom of Information Act Request (FOIA) to obtain a copy of the IRS file. Obtaining the file and analyzing the comments of the IRS employee assigned to your case will ultimately help you present a better argument to the Appeals Officer.
In cases where a formal protest letter is needed, an experienced tax attorney can help you strategize regarding how much information to include. If the Appeals Officer is in communication with your Revenue Officer or Revenue Agent, saving your best arguments until the appeals conference may play in your favor. In contrast, a detailed explanation of your position along with supporting Tax Court cases and other precedent may help expedite settlement. Picking the best method depends on your individual situation. Finally, a tax attorney demonstrates that you are serious about your case, prepared to potentially litigate the matter if a resolution is not reached, and can properly protect your rights if you are mistreated during the appeals process.
Our San Diego office can help you formulate a game plan and structure your appeal in order to obtain the best possible outcome and to potentially lower your final tax bill. Furthermore, our attorneys frequently deal with the same group of Appeals Officers and have established a good working relationship with them through our past history of cases. We can use our experience to help you obtain more favorable results.
Even if you ultimately plan to handle your own appeal, you should consult an experienced tax attorney to explain some aspects that you may not be aware of. If you are considering taking your case to the Appeals Division, please contact our San Diego office to schedule a free consultation today.
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