Your Appeal Rights When Fighting The IRS
Below is a MRR and PLR article in category Finance -> subcategory Taxes.
Understanding Your Rights to Appeal a Decision by the IRS
Are you caught in a disagreement with the IRS? It's important to know that one of your guaranteed rights as a taxpayer is the ability to appeal. Whether you're disputing the amount of your tax liability or disagreeing with proposed collection actions, you have the option to request a review by the IRS Appeals Office.
Your Right to Appeal
IRS employees are required to inform taxpayers about their rights, including the right to appeal. The IRS appeals system is designed for those who dispute the results of a tax examination or adjustments made to their tax liability. Beyond examinations, you can also appeal:
1. Collection Actions: This includes liens, levies, seizures, terminations of installment agreements, and rejected offers-in-compromise.
2. Penalties and Interest: If you disagree with the penalties or interest imposed.
3. Employment Tax Adjustments: Such as the trust fund recovery penalty.
The Appeals Process
Internal IRS appeal conferences are typically informal. Your local Appeals Office, which operates independently from the IRS, may resolve issues via phone or through correspondence.
Fast Track Mediation
The IRS offers Fast Track Mediation as an option to reach a mutually satisfactory solution. This involves an appeals or settlement officer assisting you and the IRS to resolve disagreements early on. This process is available after an audit or collection determination but before a formal appeals hearing. You can withdraw from mediation at any time, and it doesn’t replace other resolution options.
Representation During Appeals
When attending an informal meeting or pursuing mediation, you may represent yourself or choose representation by an attorney, certified public accountant, or someone enrolled to practice before the IRS.
Moving Beyond the IRS
If you cannot reach an agreement through the appeals process or choose not to appeal internally, you can take your case to federal court. However, attempting mediation first can be a more cost-effective and less time-consuming option than court proceedings.
Remember, understanding and utilizing your right to appeal can be crucial in resolving disputes with the IRS effectively.
You can find the original non-AI version of this article here: Your Appeal Rights When Fighting The IRS.
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