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Navigating the IRS Independent Office of Appeals: Achieving Favorable Settlements, Avoiding Litigation

Filing Formal Protests, Appealing Collection Actions, Requesting Collections Due Process Hearings Through Appeals

Recording of a 110-minute CPE webinar with Q&A

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Conducted on Thursday, December 14, 2023

Recorded event now available

or call 1-800-926-7926

This course will provide tax advisers and professionals with an advanced guide to navigating the IRS appeals process. The panel will go beyond the basics to offer an in-depth guide to leveraging the appeals process to challenge not only assessments but also collections proceedings. The webinar will include specific examples of navigating each stage of the appeals process.

Description

An effective vehicle for resolving taxpayer disputes is the IRS Independent Office of Appeals. While many practitioners view the Appeals Office as a last resort measure and focus on trying to reason with a revenue agent, the structure of the Appeals Office and the powers vested in an Appeals Officer may lead to a resolution that cannot be achieved during the examination, and without litigation.

The IRS Independent Office of Appeals is charged with the mission of acting to "resolve tax controversies, without litigation, on a basis which is fair and impartial to both the Government and the taxpayer." As a component of the mission to avoid litigation, Appeals Officers possess broad powers to resolve taxpayer protests and challenges.

The appeals process has several essential steps that CPAs and tax professionals must navigate. For tax advisers representing clients in IRS disputes, a thorough understanding of the policies and procedures of the Appeals Office is essential to resolving tax controversies.

Numerous policy changes have been made that impact taxpayers pursuing formal appeals. Even tax advisers who have experience practicing before the Appeals Office must be aware of these changes to avoid costly mistakes in representing clients before the Appeals Office.

Listen as our experienced panel provides a thoroughly detailed and practical guide to navigating the IRS Appeals Office process to achieve advantageous tax settlements.

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Outline

  1. Structure of IRS Independent Office of Appeals
    1. Settlement authority vested in Appeals Officers
    2. "Litigation hazards" consideration
    3. Appeal Officers' authority to reopen previously closed cases and assessments
  2. Process of filing an appeal
  3. Tactics and strategies for pursuing a claim through the Appeals Office
  4. Collection appeals and requesting a collection due process hearing or appeal
  5. Illustrations and examples

Benefits

The panel will discuss these and other critical topics:

  • What challenges may a taxpayer bring to the IRS Independent Office of Appeals?
  • How does the requirement that an Appeals Officer consider the "hazards of litigation" serve as an advantage to taxpayers and advisers in bringing an appeal?
  • When should a taxpayer docket a case before going through the appeals process?
  • Using the appeals process to challenge collection actions or address tax assessments that have not yet been challenged
  • How do recent policy and procedure changes impact taxpayers and advisers pursuing formal appeals?

Faculty

Donatello, Justin
Justin Donatello
Managing Director
KPMG

Mr. Donatello is a Managing Director in the KPMG Washington National Tax (“WNT”) Tax Controversy and...  |  Read More

Drabkin, Igor
Igor S. Drabkin
Tax Attorney & Principal
Holtz, Slavett & Drabkin

Mr. Drabkin represents tax clients in disputes with the IRS and state revenue authorities, both administratively...  |  Read More

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