IRS Appeals Representation

An IRS determination is not necessarily the final word.

Taxpayers may have appeal rights when they disagree with certain audit findings, proposed adjustments, collection actions, penalties, rejected resolution requests, and other IRS decisions. The key is understanding whether an appeal is available, what must be submitted, and how much time you have to act.

Prendamano Tax Resolution & State Tax Advisory represents taxpayers in IRS disputes from our Melville, Long Island office. We work with individuals and businesses throughout Huntington, Garden City, Mineola, Hicksville, Nassau County, Suffolk County, Queens, Brooklyn, and New York City.

The IRS Independent Office of Appeals exists to resolve qualifying tax disputes without litigation and independently of the IRS compliance function that made the original determination.

A successful appeal, however, requires more than simply telling the IRS that you disagree.

The underlying tax issue must be carefully reviewed. Supporting records may need to be organized. The government’s position must be evaluated against the facts and applicable tax law. Depending on the matter, a written protest or other formal request may also be required.

Timing is equally important.

Certain IRS collection notices provide a limited period to request a Collection Due Process hearing, and rejected Offers in Compromise also carry specific appeal deadlines. For example, the IRS states that certain collection due process requests and appeals of rejected Offers in Compromise must generally be made within 30 days of the applicable notice or rejection letter.

Because deadlines vary depending on the notice received, it is important to have the actual correspondence reviewed rather than relying on a general timeline found online.

Prendamano Tax Resolution approaches an IRS appeal strategically. We evaluate what the IRS has determined, identify the issues that can reasonably be challenged, review the supporting evidence, and present the taxpayer’s position through the appropriate process.

When significant tax liabilities are at stake, a well-prepared appeal can make an important difference.

If you received an IRS determination or collection notice that you believe should be challenged, contact Prendamano Tax Resolution & State Tax Advisory to discuss your appeal rights.