Finding Real Life Solutions To Your Tax Problem

Attorney Robert T. Leonard

Skilled Legal Help For Filing An IRS Appeal

Filing an Appeal

The issuance of a revenue agent report does not need to be the final step in the audit examination process. Timely filing an appeal and knowing what arguments to assert, documents to provide, etc. is not a process that can be done by just anyone. It takes years of experience to know the appeal process and obtain a great result. Further, it is in your best interests that your representative be well-regarded and respected by the IRS. There are a number of “mill operations” that are not respected by the IRS and, unfortunately, their clients suffer from their representative having a terrible reputation. Do not let this happen to you. Mr. Leonard has the skills necessary to represent clients with the criteria needed for a successful resolution: careful review of all the pertinent documents; understanding all of the available defenses; ability to persuade and negotiate for the very best result; commitment to resolving the problem, and great instinct and decision making at each important step along the process.

Frequently Asked Questions About IRS Appeals

If you have questions about the IRS appeal process, you may find your answers below:

What tax issues can I appeal?

Taxpayers have the right to challenge certain decisions made by the IRS if they believe these decisions are incorrect or unfair. The IRS appeal process is designed to resolve disputes without going to court. Common appeals involve:

  • IRS penalties
  • Audit adjustments
  • Collections
  • Wage garnishments
  • Offer in Compromise rejections

If you disagree with a decision made by the IRS, you may be able to file an appeal. You can speak to an experienced tax lawyer to learn about your legal options and begin the appeal process.

What evidence needs to be filed with my IRS appeal?

Depending on your tax issue, you may need to gather and submit several supporting documents for your appeal. For most audits, the IRS expects you to make a clear statement of why you disagree with the decisions they made and provide supporting evidence for your position. You may also be asked to provide bank statements and invoices alongside your appeal.

However, the specific types of documents you may need to submit may depend on the nature of the issue. For example, appealing an IRS penalty may require proof that medical issues or disasters prevented you from filing on time, including medical records or insurance claims.

The IRS may also expect you to file specific forms when filing an appeal. For instance, you may need to complete Form 12153, Request for a Collection Due Process or Equivalent Hearing or Form 433-A or Form 433-B for an Offer in Compromise when filing a collection appeal.

It helps to prepare and organize any records that may be significant for your appeal. A skilled tax attorney can help you prepare for your IRS appeal.

How long will it take to hear the results of an IRS appeal?

How long your appeal process will take may depend on the type and complexity of the case. For simple cases disputing penalties or payments, an appeal can take anywhere from six to nine months. Complicated appeals can take years to resolve, including those with complicated legal matters or tax returns spanning multiple years.

The biggest issue that can delay the appeal process is whether a case can be settled through typical negotiations or if a claim needs to escalate to court. If a tax issue is taken to court, it can add a significant amount of time to the process. However, smaller cases can be resolved sooner, especially when accurate documentation is submitted and any issues are addressed early.

Get A Free Consultation With A Tax Lawyer

Get a free, confidential assessment of your tax situation by contacting our firm at 818-485-2115. During your consultation, you will speak directly with attorney and CPA (inactive) . We represent clients in innocent spouse matters throughout California – including Westlake Village, Los Angeles and the San Fernando Valley – and across the nation.