IRS Tax Attorney Alpharetta
The most common tax and business issues that we get from the 30004 are code are for tax appeals dealing with the IRS office at the Atlanta location, or the DOR sales tax Department.
The result is often an assessment of back taxes, interest, penalties – sometimes even criminal sanctions. But those who are unlucky enough to receive unfavorable adjustment rulings from an audit have more recourse than they realize. Audits can be appealed in the same manner as lesser court rulings, and in many cases, the Office of Appeals overturns (or at least modifies) the findings of the original audit in the taxpayer’s favor.
Appeal negotiations take place in person or by mail. The negotiations are informal. An appeals officer has power to settle a dispute based on what the IRS calls the hazards of litigation. This means you’ll be more likely to get your tax bill lowered by convincing the agent there’s a significant chance the IRS will lose in tax court. The IRS considers:
- Specific facts of your case
- Chances of both you and the IRS being able to prove the facts at a trial
- The strength of your legal arguments
- The practical realities of litigating the particular issue in court
The agent looks at negotiating the specific issues involved, rather than entertaining a reduction of the overall tax bill. If there’s an agreement, the appeals agent prepares an agreement called a stipulation. You next discuss payment of the remaining tax. If you can’t reach an agreement, you can appeal the audit results to the federal tax court.
IRS appeals agents are entirely independent of the opinions and conclusions of audit agents. They have a lot of discretion in looking over audits. You could end up with a bigger tax bill than when you started.
IRS Tax Attorney Alpharetta
