The Office of Appeals is an agency in the IRS that is tasked with settling exam, collection, and other tax disputes. Appeal is tasked with resolving disputes according to the law and in a manner that balances the government’s interest to enforce and collect taxes with the taxpayer’s right that the process be fair and minimally intrusive. The right to an appeal arises upon the conclusion of an audit and during a collection matter in connection with an IRS levy or Notice of Federal Tax Lien.
If you want to dispute an IRS audit, our Denver tax attorneys will help secure the important facts and evidence and present your matter to IRS Appeals in the most advantageous light possible. Appeals settlements are often based on “hazards of litigation” – which are expressed through a % or chance of victory (or loss) on each issue. Our Denver tax attorney represented the IRS for more than 10 years in making determinations on “Hazard Settlements.” We understand what IRS hazards of litigation are and we achieve favorable results by identifying hazards and using them to settle issues.
For an IRS collection matter, the right to an IRS appeal arises through a Collection Due Process Hearing (“CDP”) or Collection Appeal Request (“CAP”). The right to a CDP arises after a Notice of Federal Tax Lien is filed and before the IRS may levy (take) your property. While the CDP is pending, IRS Collections are on hold and the taxpayer has the right to present collection alternatives and (in some instances) challenge the tax liability. Our Denver Tax Attorneys will request a Collection Due Process hearing before you lose your rights and property and, depending on your matter, will challenge the liability or secure a collection alternative (Offer In Compromise, Payment Plan, Currently Not Collectable) that will allow you to resolve your tax liability according to your personal financial ability to pay.