Appeals Representation
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When you disagree with an IRS determination, the Independent Office of Appeals offers a powerful opportunity to resolve disputes without the cost and uncertainty of litigation. Over 99% of Tax Court cases settle before trial—often through the appeals process. Effective appeals representation can save you thousands in taxes, penalties, and professional fees.
How Appeals Works
The IRS Independent Office of Appeals serves as a neutral third party within the agency. Appeals officers have more flexibility than examiners to consider the ‘hazards of litigation’—the likelihood that either side would prevail if the case went to court. This creates settlement opportunities that weren’t available during the examination.
When Appeals Is Most Effective
Appeals conferences produce the best results when the examiner failed to follow proper procedures or overlooked factual evidence, when the law contains ambiguities that could apply to your situation, when the issue involves judgment calls rather than strict legal interpretation, or when you have additional documentation that wasn’t available during the audit.
How I Approach Appeals Cases
I have tremendous respect for IRS Appeals. Appeals officers bring more experience and broader perspectives than line examiners, and they’re often willing to thoroughly review documentation when presented with well-constructed arguments. My approach focuses on comprehensive case development, clear presentation of facts and law, and strategic negotiation.
I prepare thorough written protests that clearly identify disputed issues and present the facts and law supporting your position. Understanding hazards from both perspectives helps me negotiate effectively with appeals officers and achieve favorable settlements.
A Real Success Story
One client faced a potential tax liability exceeding $550,000 after an audit. His original CPA had exhausted administrative appeals with no meaningful reduction. When I took over the case—already scheduled for Tax Court trial—I reorganized all materials into a comprehensive package that told a clear, compelling story. Six weeks before trial, IRS counsel recommended full concession. The same documentation that was previously rejected was ultimately accepted—the difference was in how it was presented.
If you’ve received an unfavorable audit determination and want experienced appeals representation, contact Boss Tax Law today.