Appeals

There are two primary avenues of tax appeals within the IRS:  Collection Appeals Program (CAP), and Request for a Collection Due Process Hearing (CDP).  Taxpayers who have missed the deadline for filing a CDP may still qualify for an “Equivalent Hearing.”  Our attorneys have extensive experience working within the IRS appeals system, and know whether, when, and how to appeal if the circumstances are such that an appeal may be of benefit to a client.  Depending upon the circumstances, an appeal may be an effective method of:  1) reversing an adverse action by the government such as a wage levy or a bank levy; 2) preventing the IRS from enforcing against a taxpayer; 3) resolving the tax liability with favorable terms; 4) obtaining more favorable terms than those that the IRS was initially willing to approve; 4) disputing the amount of tax owed; 5) challenging a variety of findings or actions of the IRS.