IRS Appeals & Collection Appeals

Challenge Unfavorable IRS Decisions

Who This Helps

  • Taxpayers seeking an IRS Small Case Request
  • Taxpayers wanting to file an IRS formal written protest
  • Taxpayers in need of an audit reconsideration
  • Taxpayers who have new documentation proving their prior decision was unjust
  • Individuals having a second opportunity to reduce their tax liability
  • Taxpayers needing a Collection Due Process (CDP)
  • Taxpayers who seek to be heard by the IRS Independent Office of Appeals
  • Taxpayers seeking remedy with the Collection Appeals Program (CAP)
  • Self-employed or business owners seeking a second opinion that is fair and impartial
  • Taxpayers seeking a suspension of collection activity during the appeal process

Need help with IRS appeals? We can help.

When the IRS makes an unfavorable determination regarding your tax liability, audit findings, or collection actions, the appeals process provides a critical opportunity for independent review and potential reversal. At Resolve Federal Tax Group, our experienced professionals specialize in navigating the complex IRS appeals system to challenge incorrect assessments, negotiate reasonable settlements and protect your taxpayer rights. The IRS Independent Office of Appeals operates independently from the collection and examination divisions, providing a fresh perspective and settlement authority that often results in more favorable outcomes. Our team understands the technical requirements for filing appeals, the procedural rules that govern hearings and the negotiation strategies that achieve optimal results. We can handle Collection Due Process (CDP) appeals, audit reconsiderations, Offer in Compromise (OIC) appeals, penalty abatement appeals and innocent spouse relief appeals with comprehensive knowledge of tax law and administrative procedures. Time limitations are critical in appeals cases, making prompt action essential to preserve your rights. Our professionals prepare thoroughly documented appeals submissions, present compelling legal arguments and advocate aggressively on your behalf before appeals officers. We can possibly successfully overturn unfavorable IRS decisions, negotiated reduced settlements and protected clients from unjust collection actions through strategic appeals representation. Don't accept an IRS determination without exploring your appeal rights. Contact Resolve Federal Tax Group for a free consultation and discover how our appeals expertise can achieve a better outcome in your case.

How We Help

1

Review Decision

We analyze the IRS decision and determine grounds for a strategic appeal

2

Prepare Appeal

We prepare comprehensive appeal documentation with legal arguments and supporting evidence

3

Represent You

We can represent you before the IRS Independent Office of Appeals, Revenue officers, in audits and collections

4

Negotiate Resolution

We can work with officers in the IRS Independent Office of Appeals to reach a favorable settlement

Common Problems & Solutions

IRS rejected your Offer in Compromise

We file Collection Due Process appeals to challenge the rejection and negotiate better terms

Facing levy or lien you believe is improper

We file Collection Due Process hearings to challenge collection actions

Received a decision letter with an appeal date

We will file for an appeal as soon as possible because usually the time to file for an appeal is limited and time is of the essence

Disagree with audit findings

We file formal appeals with the IRS Independent Office of Appeals to contest improper assessments

Need to dispute amounts up to $25,000

We file a Small Case Request to possibly remove or reduce the amount

Need to dispute amounts over $25,000

We file a Formal Written Protest to possibly remove or reduce the amount

Frequently Asked Questions

Generally, 30 days from the IRS decision, though some appeals have different deadlines. Act quickly to preserve your rights. If an appeal is not filed on time, the IRS decision will be final.

Success depends on the strength of your case and the quality of your representation. We know tax law and procedures needed to file an appeal. With correct documentation, supporting evidence and persistence the chances of success are high.

Yes, filing certain appeals (like Collection Due Process) automatically suspends collection activities during the appeal process.

Ready to Get Started?

Contact us today for a free consultation. Let us help you resolve your tax problems.

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