Appeal Channels Available To Taxpayers

By Sue Ellis


Some taxpayers have tax issues with the IRS. A taxpayer has the inherent right to appeal to the IRS if he has sufficient grounds. If in your opinion the IRS made a mistake in the evaluation of your income tax return, you may file an appeal motion for reinvestigation to the IRS Appeals Office. The IRS, being a government agency, is supposed to served the citizenry, and is obliged to accept, listen to and act on the grievances of taxpayers. The IRS appeals system is for people who do not agree with the results of an examination of their tax returns or other adjustments to their tax liability. In addition to examinations, you can appeal many other things, including collection actions such as liens, levies, seizures, installment agreement terminations and rejected offers-in-compromise, penalties and interest, and employment tax adjustments and the trust fund recovery penalty.

Among the grounds for an appeal to the IRS are the imposition of liens and encumbrances, levies, seizures, reconsideration of denied tax payment terms and proposed compromises, subjecting to or waiver of penalties and interests, and tax adjustments.

The Fast Track Mediation handles cases that are not calendared for a court hearing. You may request Fast Track Mediation at the conclusion of an audit or collection determination, but prior to your request for a normal appeals hearing. The purpose of the Fast Track Mediation is to try to resolves issues without need of an informal or formal hearing. It is only one of several channels available to a complaining taxpayer and is not meant to replace or supplant other complaint avenues in the IRS. A taxpayer can desist from pursuing the mediation proceedings anytime.

The taxpayer can choose to take his appeal to the IRS by himself or with assistance from a lawyer, a certified public accountant or an IRS enrolled tax agent.

If you and the IRS appeals officer cannot reach agreement, or if you prefer not to appeal within the IRS, in most cases you may take your disagreement to federal court. A court case however is inconvenient and costly and is resorted to only as a last option by the taxpayers.




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