tax dispute resolution
  • March 15, 2017
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Any discrepancy in the involved tax collection, proposed tax assessments, or other IRS actions can increase a taxpayer’s grievances. Once you receive a final notice from the IRS, you may seek tax dispute resolution through legal intervention. Filing appeals is a preferable, yet less formal approach than other court proceedings, but is independent of judicial mandates of evidence or procedure. In the past, appeals have helped settle a significant number of cases. Let us take a closer look at the various aspects of Appeals, and how you can benefit from the process.

Must Read: IRS Appeal, Appeal Issues, and Appeal Tax Relief

What is an appeal?

Created in 1927, the Internal Revenue Service (IRS) Office of Appeals (Appeals) is responsible for the resolution of tax disputes without litigation, or on grounds that are fair and impartial to both the taxpayer and Government. Appeals, therefore, help in enhancing voluntary compliance and instill confidence in the general public in the efficiency and integrity of the IRS.

Must read: Tax Lien vs. Tax Levy: Examining the Differences

Preparing a Request for Appeal

If you do not agree with your tax determination, you may request an Appeals conference by filing a written certified public accountant, attorney, or authorized agent practicing before the IRS. Such rep complaint. You may represent yourself, or have professional representation. The professional should be are sentatives must produce a copy of a power of attorney: Form 2848, also known as the Power of Attorney and Declaration of Representative.

Consider following points, to help you decide whether to take your case to the Appeals conference:

  • If you believe that the IRS has made an incorrect decision, based on a misinterpreted law, check the publications that cover your issue or refer to Tax Topics.
  • If you believe the IRS has inappropriately applied the law due to an incorrect understanding of facts, you should support your view in the appeals forum.
  • If you believe the IRS is taking inappropriate action to collect tax from you, or your offer to compromise has been denied, you should support your view in the appeals forum.
  • If you believe that the IRS is citing incorrect facts, then you must produce evidence to support your position in an Appeals forum.

What Can You Expect from Appeals?

Once your case qualifies for an appeal, an Appeals agent will review it and schedule a conference with you. Appeals conferences are informal and conducted through correspondence or over the telephone. Differences are often settled without going to trial. Reasons for disagreement that are sufficient for the Appeals to consider your case include, political, religious, constitutional, and conscientious objections. In addition, you must provide all relevant information and requested documentation to the auditor or revenue officer working on your tax dispute resolution.

The Bottomline

According to the IRS Restructuring and Reform Act of 1998, the IRS Commissioner is directed to develop and implement plans to reorganize the IRS, by establishing organizational units that cater to particular taxpayer segments with similar needs. It also specifies that a self-sufficient Appeals function must be included within the IRS that is free from any “ex parte” communications between Appeals auditors and other IRS employees. Through this provision, the Appeals avoids any conflict of interests or compromises with the IRS, helping resolve common taxpayer grievances. To learn more about tax dispute resolution and Appeals, fill out our contact form, and we will get back to you shortly.Or please feel free to call our office and schedule a, no-obligation, free consultation with Attorney Nick Nemeth.(972) 426-2553.

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What Our Clients Have to Say

Susan WilsonSusan Wilson
03:27 25 Jan 23
I have been very pleased with the solid counsel and guidance that Nick Nemeth has provided me regarding my tax issue. I found him to be honest and straightforward which I appreciated. I was impressed with his relevant experience and knowledge . He has definitely brought me peace of mind during a difficult and stressful time.
Sarah HowardSarah Howard
03:44 14 Nov 22
I would like to thank Mr. Nick and his staff for the superb help that I received from them. My IRS problem was resolved quickly and efficiently. It took 2 visits to convince me that I was over my head. I thought that I could call the IRS, appeal my tax notices and settle on a payment plan on my own. After many phone calls to the IRS, waiting sometimes more than 4 hours with no resolution to speak of, it proved to be extremely difficult and stressful. Revisiting Mr. Nick was a huge wake up call. My account was reviewed, and a payment plan was established with the IRS within a week. I will be forever grateful to the staff who worked on my case and especially to Lorna who listened to me vent while going through this painful process.
00:33 07 Aug 22
I cannot say enough good things about Nick and his team. When I first met with Nick he was up front, honest, friendly and efficient. When I worked with one of his attorneys, Eric B, I was just as pleased. All of the staff there are nice and very helpful. I wish I hadn't waited so long to get help with my issue. Over 6yrs I tried getting through and getting anywhere with the IRS and hardly made any progress. I know this may not be the case for all, and even I thought it would take longer than it did, but 3mos and they had my situation straightened out. I still can't believe it. Thank you thank you THANK YOU for all that you did for me. This is a huge burden gone out of my life now thanks to you. If anyone needs help out there, I know you may not want to shell out more money to get their help but it may just save you in the long run.
Spoilly GirlSpoilly Girl
23:49 03 Aug 22
The Nemeth Law team is exceptional. They treat their clients like a family member who is in crisis. They want you to get the best possible outcome. I really appreciate everything that they did for me. Jake and Ashley had the greatest role in my case and it all turned out for the best for me. Thank you Nick and team for easing my fears and getting me through the long process. I'm truly grateful.
Eddie WaltEddie Walt
19:44 12 Jul 22
During a time in which competent, professional service at a fair price seems to have disappeared, Mr. Nemeth and his team are a refreshing breath of fresh air.From my first phone call to the final settlement of our case with a non-responsive IRS, they under-promised, over-delivered and were in constant courteous contact to make sure we knew exactly what was happening and where we stood.I hope to never need their services again, but, should I receive another friendly letter from the IRS...I know who to call!
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