IRS APPEALS
When the audit ends badly, the case is just starting.
The IRS Office of Appeals is independent from the examination function — and that independence is where most administrative tax cases are won. We represent clients through the full Appeals process: protests, conferences, and settlement. If Appeals does not resolve the matter, our Tax Court practice takes it from there.
WHAT WE DO
A different forum. A different conversation.
Appeals Officers are not auditors. Their mandate is to resolve cases on a basis that is fair to the government and fair to the taxpayer — and they have the authority to weigh hazards of litigation that examination cannot.
That changes what the case looks like. The written protest is the most important document the IRS will read about your matter. We treat it that way: a clear factual record, the right legal authorities, and a candid assessment of where the case would go in court.
Appeals matters we handle
- Protests of proposed examination adjustments (30-day letters)
- Collection Due Process (CDP) and equivalent hearings
- Innocent spouse appeals
- Penalty abatement appeals
- Trust fund recovery penalty appeals
- Offer in compromise appeals
- Fast-track settlement and post-Appeals mediation
For cases that proceed past Appeals — or where the statutory notice is already in hand — see our U.S. Tax Court litigation practice.
INSIDE EXPERIENCE
A former IRS Appeals Officer on your side of the table.
Kreig Mitchell worked inside the IRS as an Appeals Officer. He knows what an Officer is required to consider, what Appeals will and will not settle, and how a case has to be framed to give the Officer room to resolve it.
That perspective shapes every protest we write. We do not draft for the examination team — we draft for the person who will actually decide the case.
Holding a 30-day letter or Appeals notice?
There are deadlines, and there are doors that close once the deadlines pass. Talk to an attorney before they do.