Appeals of IRS Collections
Challenge Unfair IRS Decisions and Collection Actions
If you disagree with an IRS determination, you have the right to appeal. Axio Tax Relief provides expert representation throughout the appeals process.
Understanding IRS Appeals
An IRS appeal is your opportunity to challenge an IRS decision you believe is incorrect or unfair. The IRS Office of Appeals is an independent organization within the IRS that resolves disputes between taxpayers and the IRS without going to court.
Appeals are available for many types of IRS determinations, including audit results, collection actions, penalty assessments, Offer in Compromise rejections, lien and levy actions, and innocent spouse relief denials. The appeals process provides a fresh, impartial review of your case by an appeals officer who wasn't involved in the original decision.
Successfully appealing an IRS decision requires a thorough understanding of tax law, strong documentation, and persuasive arguments presented in the proper format. Professional representation significantly improves your chances of a favorable outcome.
What Can You Appeal?
Audit Results
Challenge proposed tax changes, additional taxes, penalties, or interest resulting from an IRS examination.
Collection Actions
Appeal levies, liens, seizures, and other collection actions through a Collection Due Process hearing.
Penalty Assessments
Challenge penalties for late filing, late payment, accuracy-related issues, and other violations.
OIC Rejections
Appeal denial of your Offer in Compromise application and present additional evidence.
Innocent Spouse Denials
Challenge denial of innocent spouse relief and argue for your protection from joint liability.
Trust Fund Penalties
Appeal Trust Fund Recovery Penalty assessments for unpaid payroll taxes.
Types of IRS Appeals
Examination (Audit) Appeals
If you disagree with the results of an IRS audit, you can appeal by filing a written protest or requesting an Appeals Office conference. This gives you a chance to present your case to an independent appeals officer.
Collection Due Process (CDP) Hearings
When the IRS issues a Notice of Intent to Levy or files a tax lien, you have the right to a CDP hearing to challenge the collection action and propose alternatives.
Collection Appeals Program (CAP)
CAP provides an informal process to quickly resolve certain collection issues, such as lien releases, levy releases, and installment agreement rejections.
Offer in Compromise Appeals
If your OIC is rejected, you can appeal the decision to the IRS Appeals Office to present additional evidence or arguments supporting your offer.
How Axio Tax Relief Handles Your Appeal
Case Review and Analysis
We thoroughly review the IRS decision, identify errors or unfair determinations, and assess the strength of your appeal.
Written Protest Preparation
We prepare comprehensive written protests that clearly articulate why the IRS decision is incorrect, supported by relevant facts, law, and evidence.
Appeals Conference Representation
We represent you at appeals conferences, presenting your case persuasively and negotiating with the appeals officer on your behalf.
Evidence and Documentation
We gather and organize all necessary documentation, expert opinions, and legal authorities to support your position.
Settlement Negotiation
If appropriate, we negotiate settlements with the appeals officer to achieve a favorable resolution without further litigation.
Why Professional Representation Matters
The IRS appeals process is formal and complex. Appeals officers are experienced in tax law and negotiation. Without proper representation, you're at a significant disadvantage.
Axio Tax Relief's experienced tax professionals know how to present your case effectively, identify weaknesses in the IRS position, and achieve the best possible outcome through the appeals process.
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