IRS APPEALS
The Independent Office of Appeals sits between the examining function and the courthouse. It is the last place a dispute can be resolved without a judge, and it settles on a standard the examination function does not apply: the hazards of litigation.
That distinction is the whole opportunity. Examination asks whether the position is correct. Appeals asks what would happen if the case were tried, and settles accordingly.
Thirty-day letter in hand?
It is an invitation to Appeals that expires. The protest you file is the document the settlement is priced from.
Scheduling does not create an attorney-client relationship. No such relationship exists until the firm has run a conflicts check and both sides have signed a written engagement agreement.
THE THIRTY-DAY LETTER
A thirty-day letter is an invitation to Appeals with an expiration date. Letting it lapse does not end the matter; it moves the matter to a statutory notice of deficiency and the ninety-day clock, with one fewer forum available to resolve it.
WHAT THE FIRM DOES
Drafts the written protest
the document that frames the case for the Appeals officer and, in practice, sets the ceiling on the settlement
Develops the litigation hazards honestly
because an Appeals officer discounts a hazards argument that is not real
Represents the taxpayer at the conference
Preserves the record for the United States Tax Court if Appeals does not resolve the matter
COUNSEL WHO CAN TRY THE CASE
A hazards-of-litigation settlement is a negotiation about what a court would likely do. That negotiation is conducted differently by a representative who could file the petition and try the matter, and by one who could not.
The detailed procedure is set out in The Appeal Station.
Examination asks whether the position is correct. Appeals asks what a court would do.
HOW AN ENGAGEMENT BEGINS
Book a free consultation
Thirty minutes, no charge. Bring the notice — we read it together on that call.
The deadline is identified
Which notice it is, what it asserts, and which forums are still open behind it.
Conflicts check and written engagement
Scope and fee agreed in writing before any work begins.
HOW A CONTROVERSY RESOLVES
The firm takes over
Correspondence with the Service runs through the firm. You stop answering.
The position is built and pressed
Records, authority, and the argument — pressed at the earliest stage that will take it, because that is the cheapest place to win.
Resolution
Closed at examination, settled at Appeals on the hazards, or tried. The firm does not hand the file to anyone to reach the last of those.
A protest is the document the case is ultimately decided on. Contact the firm through the contact page or call (561) 529-5873. Representative engagements are described on the Experience page.