Are you looking for an IRS appeal lawyer in Hanover, MD?
At Crepeau Mourges, we invite you to schedule a consultation with an experienced Hanover IRS appeal lawyer today.
If you disagree with the outcome of an audit, a penalty, or a collection action, you do not have to accept it. The IRS maintains an administrative appeals process, and taxpayers who use it correctly often reach far better results than those who simply pay or ignore the notice. A Hanover, MD IRS appeal lawyer at Crepeau Mourges can evaluate the government’s position, preserve your deadlines, and argue your case before the Independent Office of Appeals. Consultations are free.
IRS Appeal Lawyer Hanover, MD
An IRS appeal attorney challenges agency decisions through the administrative review process. The Independent Office of Appeals operates separately from the examination and collection functions that made the original decision. Its stated mission is to resolve disputes fairly and impartially, without litigation. Appeals officers can weigh the hazards of litigation, which means they have authority to settle cases based on the risk the government would lose in court.
That authority is what makes an appeal worth pursuing. An examiner cannot compromise. An appeals officer can. But the process is deadline-driven and built on the written record, so the strength of your protest often decides the outcome before anyone sits down to talk.
Types of IRS Appeal Cases We Handle in Hanover
Nearly every adverse IRS decision carries appeal rights, though the procedures differ depending on what you are challenging. Our firm represents individuals, businesses, and estates across Hanover, MD in each of them.
- Examination appeals. When an IRS audit ends with proposed adjustments you dispute, a 30-day letter opens the window to file a written protest. We draft protests that frame the legal and factual issues an appeals officer will actually weigh.
- Collection Due Process hearings. A CDP hearing lets you challenge a lien filing or proposed levy before enforcement moves forward. We use these hearings to raise payment alternatives and, in some cases, the underlying liability itself.
- Collection Appeals Program requests. CAP offers a faster review of specific IRS collection actions, including levies and installment agreement terminations. It trades speed for a narrower scope, and we advise clients on which path fits.
- Penalty abatement appeals. The IRS denies many reasonable cause requests at the first level. We appeal those denials with documentation showing why the penalty should not stand.
- Offer in compromise appeals. A rejected offer is not the end of the negotiation. We challenge rejected offers and the financial calculations behind them.
- Lien and levy appeals. Liens and levies can be withdrawn, released, or subordinated in the right circumstances. We pursue IRS tax lien relief through every available channel.
- Innocent spouse appeals. When the IRS denies innocent spouse relief, the requesting spouse can appeal that determination. The record decides these cases, and we build it carefully.
- Trust fund recovery penalty appeals. Business owners and officers assessed personally for unpaid payroll taxes can contest both responsibility and willfulness. We defend these assessments at the protest stage.
- Tax Court petitions. If Appeals cannot resolve the case, a notice of deficiency permits a petition to the U.S. Tax Court. We litigate when settlement fails.
Why Choose Crepeau Mourges as my IRS Appeal Lawyer in Hanover, MD?
Attorneys Built for Tax Controversy Work
Appeals are won on the strength of the written protest and the credibility of the advocate presenting it. Brandon N. Mourges earned his LL.M. in Taxation from the University of Baltimore School of Law after completing his economics degree at Wharton. He writes and speaks frequently on tax controversy issues, has been featured by Bloomberg and the Tax Section of the Florida Bar, and received a pro bono service award from the Maryland State Bar Association. Brian J. Crepeau has handled federal and state tax controversies for individual and corporate taxpayers since 2003, with a background in fraud examination and income analysis that appeals officers take seriously. Our founding attorneys bring more than 40 years of combined experience to every matter our IRS tax lawyer in Hanover, MD handles for our clients.
Results Reached Without Trial
Most of our appeal matters resolve at the administrative level, which saves clients the cost and exposure of litigation. Our firm has helped taxpayers reduce assessments, remove penalties, and stop enforcement actions. When a case does need to go to court, we are prepared to take it there.
Understanding IRS Appeal Cases
Deadlines, Protests, and Settlement Authority in IRS Appeal Cases
The appeals process rewards preparation and punishes delay. The rules governing protests and conferences are described in IRS Publication 5, and a few core concepts drive nearly every case:
- Most examination appeals begin with a 30-day letter. Missing that window usually forfeits administrative review.
- A notice of deficiency provides 90 days to petition the Tax Court. That deadline is jurisdictional and cannot be extended.
- Formal written protests are generally required for larger disputes, while smaller cases may qualify for simplified requests.
- Appeals officers may settle based on litigation risk, something no examiner can do.
- Collection appeals follow their own procedures, described in the IRS collection appeal rights materials.
- Interest continues to accrue while an appeal is pending, which affects settlement strategy.
What Are Important Aspects of an IRS Appeal Case?
An appeal is not a second audit. It is a negotiation with a government officer whose job is to close cases, and IRS tax appeals succeed when the taxpayer gives that officer a documented reason to settle. Several things matter from the start.
- The protest frames everything. Issues left out of the written protest are difficult to raise later.
- New evidence can send the case back to the examiner, so the record should be complete before filing.
- Credibility carries weight. Overstated positions weaken the arguments that actually have merit.
- Litigation risk cuts both ways, and a realistic assessment of your own case is worth more than optimism.
What Is The IRS Appeal Case Timeline?
Appeals take time. Simple penalty cases may resolve in a few months, while complex examination appeals commonly run a year or more. The sequence, though, is fairly consistent.
- The IRS issues a decision letter that triggers appeal rights and starts a filing deadline.
- The taxpayer files a protest or hearing request setting out the disputed issues.
- The case transfers to the Independent Office of Appeals and is assigned to an officer.
- A conference is held, by phone, video, or in person, where positions and settlement ranges are discussed.
- The case closes by agreement, or a final determination issues and litigation deadlines begin.
What Should You Bring to Your IRS Appeal Consultation?
Because deadlines control appeal rights, bring your documents to the first meeting even if they are incomplete.
- Every IRS notice or letter you have received, with envelopes showing mailing dates
- The examination report or decision you want to challenge
- Tax returns for the years involved
- Records supporting your position on each disputed item
- Any prior correspondence with the examiner or collection officer
At your free consultation, we will identify which deadlines apply, whether an appeal is the right vehicle, and what a realistic outcome looks like.
What Are Important Maryland Legal Resources for IRS Appeal Cases?
Reliable information about the appeals process comes directly from the agencies that run it. These resources explain your rights in plain terms.
- The IRS explains the process on its considering an appeal page.
- The Taxpayer Advocate Service assists taxpayers facing hardship or unresolved disputes.
- The U.S. Tax Court publishes guidance for taxpayers who petition after Appeals.
- The Comptroller of Maryland governs the state-level appeals that often parallel federal cases.
Reach Out to Crepeau Mourges to Schedule a Consultation
Appeal rights expire on fixed dates, and the notice in your hands already lists one. Contact us to schedule a free consultation with an IRS appeal attorney in Hanover, MD. We will read the notice, map your deadlines, and tell you plainly whether an appeal makes sense in your situation. New inquiries receive a prompt response from our office.
