Not every dispute with the IRS needs to end up in court. In many cases, the IRS Independent Office of Appeals offers taxpayers a meaningful opportunity to resolve disagreements through an administrative process that is typically less formal, less expensive, and faster than litigation. Appeals is separate from the IRS examination and collection functions, and its mission is to resolve tax controversies fairly and impartially without going to court when possible. A Howard County, MD tax lawyer can help taxpayers navigate the IRS appeals process, protect their rights during disputes with the IRS, and work toward a fair resolution based on the facts and applicable tax law.
Administrative appeals may be available in a wide range of matters, including audit disputes, certain penalties, collection actions, and rejected settlement proposals. In many situations, the process begins after the taxpayer receives a letter offering appeal rights or a deadline to file a protest. At that point, the quality of the written submission becomes very important. A well-prepared protest should explain the facts, the law, the disputed issues, and the reasons the IRS’s position should be changed.
One reason Appeals can be effective is that it often evaluates cases with an eye toward the “hazards of litigation.” In other words, Appeals may consider the strengths and weaknesses of both sides and whether a court would likely agree with the IRS on every issue. That makes Appeals different from the original examining or collecting function. It also creates room for practical, negotiated resolutions that might not have been possible earlier in the case.
For many taxpayers, the appeals process is a valuable chance to resolve a matter before the cost and uncertainty of litigation. It can also preserve flexibility, because pursuing an administrative appeal does not always eliminate later court options. The key is to act within the required deadlines and present the case strategically. When used effectively, administrative appeals can save substantial time and expense while still producing a fair result.
At Crepeau Mourges, we have successfully resolved tax disputes of all types and in all amounts without the need for expensive litigation. While we are fully capable of litigating to success, resolutions with Appeals can be more favorable than possible outcomes in litigation, before considering of time and cost savings. Call us today to put our experience and knowledge to work for you.
