APPEALS
The Tax Law Practice specialize in appeals. The Appeals mission is to resolve tax controversies, without litigation, on a basis which is fair and impartial to both the Government and the taxpayer in a manner that will enhance voluntary compliance and public confidence in the integrity and efficiency of the Service. Below are some of the
areas that we specialize in:
Examination Appeal
The IRS has an appeals system for people who do not agree with the results of an IRS examination of their tax returns or with other tax adjustments made by the IRS to their tax liability. If you are involved in a tax audit with the IRS, make sure you know and understand all your rights to an appeal from an IRS decision.
Please follow this link to find out more regarding an Examination Appeal
Collection Appeals Program
From 1992 to 1994, the Internal Revenue Service tested various appeal procedures for collection actions. On April 1, 1996, the Service implemented, nationwide, a Collections Appeals Program, CAP for short, which provides for appeals of liens, levies, and seizures. Appeal procedures already in place for alternative methods of collection, such as the imposition of the trust fund recovery penalty or appeals of rejections of offers in compromise, are not included in this program, and remain subject to their own previously established IRS appeals procedures.
Please follow this link to find out more regarding a Collection Appeals Program
Collection Due Process Hearing
We find this CDP Hearing process to be extremely helpful to clients in contesting and preventing inappropriate IRS collection action. The Appeals Officer is someone entirely outside the IRS Collection Division who takes an impartial look at the case to determine whether the proposed collection action (levy, seizure, etc.) is appropriate.
Please follow this link to find out more regarding a Collection Due Process Hearing
Offer In Compromise Appeal
If your Offer In Compromise is rejected you should consider appealing it. This is something that many people don't realize is possible, but it can help you get what you want - with just a little more work. Understand that you typically have 30 days from the date on the reject letter to appeal it.
Please follow this link to find out more regarding an Offer In Compromise Appeal
Trust Fund Recovery Penalty (TFRP)
To encourage prompt payment of withheld income and employment taxes, including social security taxes, railroad retirement taxes, or collected excise taxes, Congress passed a law that provides for the TFRP. These taxes are called trust fund taxes because you actually hold the employee's money in trust until you make a federal tax deposit in that amount. The TFRP may apply to you if these unpaid trust fund taxes cannot be immediately collected from the business. The business does not have to have stopped operating in order for the TFRP to be assessed.
Please follow this link to find out more regarding an Trust Fund Recovery Penalty
Please feel free to contact us at your earliest convenience to discuss you case.