IRS Tax Appeals Lawyer for the IRS Independent Office of Appeals

IRS Tax Appeals Attorney

The IRS gives taxpayers the right to appeal a vast range of IRS decisions, determinations, and collection actions – but the process is deeply complex, procedural, and bound by strict deadlines. When you want to dispute an IRS decision, you need the right legal team to protect your interests and secure the best outcome possible. 

We can help. At Seattle Legal Services, PLLC, our attorneys have extensive experience with the appeals process, and we’ll work hard to get you the best outcome possible. Contact us at any time, either online or by calling 425-428-5262. The sooner you call, the more options you’ll have and the more we can help you. 

When To Consider Filing an IRS Appeal 

You should consider an appeal any time you disagree with an IRS decision, but keep in mind that the available process, the most effective option, and the best path forward depend on the situation – that’s why the right legal team is critical. 

The IRS Independent Office of Appeals (Office of Appeals) is the IRS’s primary division or department to handle taxpayer appeals. The right to file an appeal with the Office of Appeals usually arises if the following three conditions exist:

  • The letter or notice from the IRS explains your right to appeal,
  • You want to dispute the IRS’s decision or conclusion, and
  • You decline to sign the agreement form that the IRS has sent you.

Contact our attorneys about an appeal if you’re dealing with:

Our legal team ensures you get the best representation possible through the appeals process, leveraging our experience and knowledge of the tax code. However, we also advise our clients when an appeal isn’t the right option and a different approach may be better.

Whether it’s filing a petition with the U.S. Tax Court or applying for a different form of tax relief, we provide strategic evaluations for all our clients. 

Types of Appeals We Handle 

At Seattle Legal Services, we handle a variety of tax appeals, such as:

  • Audit Appeals: This includes challenging proposed changes before a tax assessment, as well as disputing IRS audit determinations.
  • Unpaid Tax Collection Appeals: We can help you decide between requesting a Collection Due Process (CDP) Hearing or making use of the Collection Appeals Program (CAP), and then help you through the appeals process.
  • Offer in Compromise Appeals: Our tax professionals have experience disputing the IRS’s financial analysis and correcting the misapplication of the law.
  • Innocent Spouse Appeals: If the IRS incorrectly denies the requested relief or improperly applies the relief, we can step in to fix things.
  • Trust Fund Recovery Penalty Appeals: If there’s a flaw in the IRS’s responsible party determination, we’ll help find it. We can also defend against accusations that the nonpayment of trust fund taxes was willful.

Don’t see your concern on the list? Our attorneys can still help. When you schedule a consultation, we’ll learn about what you’re facing and let you know what our team can do. 

Filing an IRS Appeal Is More Than Just Filling Out a Form 

In some cases, you can file an appeal by filling out a form or making a phone call to the IRS. But other times, making the most of the appeal requires careful financial and legal analysis and presenting the strongest arguments possible with the proper documentation to support your position.

Remember, when you’re in the appeals stage, the IRS has already made a determination or decision. To appeal, you have to argue why that decision was incorrect to an independent body of the IRS. Here’s how our experience helps:

  • Knowledge of the Internal Revenue Code: Successful appeals often hinge on advanced knowledge of the IRC. Let us leverage our education and training for you. 
  • Procedural compliance: Missing deadlines or filing requirements can mean losing appeal rights and risking collection actions. Our experience ensures the compliance your case needs to move forward.
  • Understanding the options: The success of your case also hinges on understanding which appeal option is the best to pursue, in light of time constraints, cost, complexity, the right to appeal the decision to a higher authority, and the appeal’s effect on the IRS’s right to continue collection actions. 

The bottom line is that the IRS rules need to be carefully adhered to, and nuanced negotiating and strategic thinking are required to make the most of the IRS appeals process. That’s why you need attorneys deeply experienced with the appeals process. 

Filing an Appeal vs. Going to Court 

Besides filing an appeal with the IRS Office of Appeals, you might also have the option of going to the U.S. Tax Court. This is a more formal way of contesting an IRS action and is sometimes more likely to get the tax relief you seek. 

Our tax professionals can help you decide which approach is best by evaluating the merits of your legal arguments and conducting a cost/benefit analysis that takes into account your bottom line and risk tolerance.

How Seattle Legal Services Handles Appeals 

If you hire Seattle Legal Services to handle your IRS appeal as an individual taxpayer, our attorneys will provide:

  • Case and tax transcript analysis.
  • A review of your tax assessment history and procedural posture.
  • Strategic determination of best appeal pathways.
  • Preparation of formal written protests.
  • Protection of relevant appeal deadlines.
  • Direct communication and negotiation with the IRS Independent Office of Appeals.
  • Evaluation of post-appeal options, including filing a Tax Court petition where appropriate.

If you’re a business taxpayer, you can also expect:

  • Payroll tax assessment challenges.
  • Trust Fund Recovery Penalty defense.
  • Negotiations with IRS revenue officers.
  • Installment agreement and OIC negotiations.
  • A focus on both protecting your business operations and you from personal liability. 

Seattle-Based, Nationwide Service 

We’re based in Seattle, but we can help any taxpayer in the United States with their IRS tax issues. And if you’re located in Washington State, we can also help you with your WA Department of Revenue tax problems. 

Get Representation For Your IRS Tax Appeal 

Deciding when to appeal is sometimes as difficult as figuring out how to file and arguing your appeal before the IRS. This is why it’s important to get the right type of tax help when making these decisions. You can get this help, and more, by contacting Seattle Legal Services, PLLC. 

Our attorney-led tax team will thoroughly examine your case and assist you in deciding if and how to submit an appeal to the IRS. To schedule a free consultation, you can call us at 425-428-5262 or use our online contact form.