IRS Appeals

Appeals Officers are often more experienced than the Revenue Agents who handle audits. A majority of disputed audits are settled during the appeals process. An aggressive and knowledgeable tax lawyer can provide the taxpayer the leverage needed to make a difference in the settlement offered during the appeals process. Like the taxpayers themselves, the IRS does not want to litigate these issues because of the time, expense, and risk of an unfavorable outcome. When the IRS loses a case, it sets a precedent for many taxpayers for many years, and therefore the IRS does not want to set a negative precedent for government. If the matter cannot be settled at appeals, the Appeals Officer will issue a Notice of Deficiency or 90-Day Letter. You can proceed to the U.S. Tax Court without paying the alleged tax owed if you file your petition in the Tax Court within 90 days of the issuance of the Notice of Deficiency. If you do not file a petition in Tax Court within 90 days, the proposed tax changes, interest, and penalties become assessed and owed.