Archive for September 2024

IRS Independent Office of Appeals  Additional Information on your right to appeal (Part I) Taxpayer Advocate Service (TAS) Assistance The TAS is an independent organization within the IRS that helps taxpayers and protectstaxpayers’ rights. TAS can offer free help if your tax problem is causing a financial difficulty, you’ve tried but areunable to resolve your…

IRS Independent Office of Appeals  Recovering Administrative and Litigation Costs (Part IV) You are not the prevailing party if: The United States establishes that its position was substantially justified. If the IRS does not follow applicable published guidance, the United States is presumed to not besubstantially justified. This presumption is rebuttable. Applicable published guidance means…

IRS Independent Office of Appeals  Recovering Administrative and Litigation Costs (Part III) To qualify as a prevailing party, you must: -Substantially prevail on the amount in controversy or the most significant issue(s)presented, or obtain a final judgment that is less than or equal to a “qualified offer” thatthe IRS rejected, AND– Meet the applicable net…

IRS Independent Office of Appeals  Recovering Administrative and Litigation Costs (Part II) Recoverable litigation or administrative costs may include: -In general, attorney fees that do not exceed a maximum hourly rate, which changes fromyear to year. Fees in excess of the maximum can be awarded in limited circumstances.– Reasonable amounts for court costs or any…