Posts by Ruth Ann Michnay, P.A.

IRS Independent Office of Appeals  Other Options – Court Action If you do not appeal your case within the IRS, or were unable to reach a settlement with Appeals,you may be able to take your case to one of the following courts if you satisfy the court’sprocedural and jurisdictional requirements:– United States Tax Court-United States…

IRS Independent Office of Appeals    The Appeals Conference (Part II) If you want your representative to participate in an appeals conference without you, you must provide a properly completed power of attorney to the IRS before the representative can receive or inspect confidential information. You can use Form 2848, Power of Attorney and Declaration…

IRS Independent Office of Appeals    The Appeals Conference (Part I) Appeals conferences are held in an informal manner. Appeals will contact you and/or your authorized representative to arrange a conference at a convenient time. You may represent yourself at your appeals conference, or you may appoint a person authorized to practice before Appeals to…

IRS Independent Office of Appeals    What is their function within the IRS? Appeals is an independent function of the IRS, separate from the division of the IRS that proposed the changes. It is the only level of administrative appeal within the IRS. Appeals employees fairly and impartially settle disputes between taxpayers and other divisions…

IRS Independent Office of Appeals:    Appeals Mediation Programs Part VI Formal Written Protest (continued) Alert: Representatives who submit the protest must use the applicable penalties of perjury statement below, based upon whether they have personal knowledge regarding the information stated in the protest and accompanying documents:  Your (or your representative’s) signature under the penalties…

IRS Independent Office of Appeals:    Appeals Mediation Programs Part V Formal Written Protest (cont) In your formal protest, include a statement that you want to appeal the changes proposed by the IRS and include all of the following: “Under penalties of perjury, I declare to the best of my knowledge and belief, the information…

IRS Independent Office of Appeals:    Appeals Mediation Programs Part IV Formal Written Protest A formal written protest is required if the proposed change to the total amount of tax and penalties for any tax period is more than $25,000 in the letter you received. The total amount includes the proposed increase or decrease in…

IRS Independent Office of Appeals:    Appeals Mediation Programs Part III Small Case Request If the total amount of tax and penalties for each tax period involved is $25,000 or less in the letter you received, you may make a small case request instead of filing a formal written protest. See next week’s Tuesday Tax…

IRS Independent Office of Appeals:    Appeals Mediation Programs Part II Protests You must submit a written protest to request an Appeals conference. The Appeals employee assigned to your case will use your protest to prepare for the Appeals conference. Refer to Notice 609, Privacy Act Notice, for more information about how the IRS uses…

IRS Independent Office of Appeals:    Appeals Mediation Programs Part I In certain IRS cases, you may request an expedited dispute resolution process called Fast Track Settlement (FTS). The disputed issue must be fully developed and the IRS must agree to participate in this process. During FTS, your case remains in the examiner’s jurisdiction while…