IRS Tax Appeals New York
The Internal Revenue Service has an appeals system for taxpayers who do not agree with the results of an examination of their tax returns or with other adjustments to their tax liability. In addition to examinations, many other things can be appealed, among them are: - Collection actions such as liens, levies, seizures, installment agreement terminations, and rejected offers in compromise – Penalties and interest – Employment tax adjustments and the trust fund recovery penaltyThe Appeals Office is separate from the IRS Office taking the action you disagree with. The Appeals Office is the only level of administrative appeal within the IRS. Conferences with Appeals Office personnel are held by correspondence, by telephone or at a personal conference.An Appeals Officer will review the strengths and weaknesses of the issues in your case and give them a fresh look.
Appeals will consider any just reason you have for disagreeing, except for moral, religious, political, constitutional, conscientious objection, or similar grounds.Although a taxpayer’s right to appeal is guaranteed, the IRS imposes strict requirements as to when a taxpayer’s request for appeal (sometimes called a “Tax Protest”) must be filed. The filing period for filing the Tax Protest is generally 30 days from the date of the IRS Notice identifying the agent’s findings and offering to appeal these findings to the Appeals Office.If you decide to do nothing or fail to timely file a Tax Protest and your case involves an examination of your income, estate, gift, and certain excise taxes or penalties, you will receive a formal Notice of Deficiency. The Notice of Deficiency allows you to appeal the IRS’ findings to the Tax Court. If you do not go to the Tax Court, you will have waived your rights to appeal the findings and the IRS will send you a bill for the amount due.If you decide to do nothing or fail to timely file a Tax Protest and your case involves a trust fund recovery penalty, or certain employment tax liabilities, the IRS will send you a bill for the penalty. If you do not appeal a denial of an offer in compromise or a denial of a penalty abatement request, the IRS will continue collection action.
Mr. Cotton is familiar with the IRS and knows how to present your appeal with legal argument and tax authority. If you do not agree with the result of your examination by the IRS and want to file an appeal - PLease feel free to contact.