If the IRS has made a decision you don’t like or strongly disagree with – don’t give up. You may have the right to appeal, and our team can help. 

Our tax attorneys can help you navigate appeals for proposed assessments, collections, and most other IRS decisions. If an appeal isn’t available, we’ll develop another strategy to help you get relief. Don’t wait – contact The W Tax Group for a consultation today.

You Need Our Appeals Services If…

Wondering if our services can help you or if an appeal is even the right strategy? Our appeals services can help if you’re dealing with:

• Proposed tax or penalty assessment – due to an adjustment on your return, an audit, or a Substitute for Return in a year you didn’t file.
• IRS Notice of Deficiency – related to tax assessments as noted above.
• Notice of Federal Tax Lien – filed as a public record and attaches to all assets.
• Final Notice of Intent to Levy – gives the IRS the right to seize wages and levy assets if you don’t appeal by the deadline.
• Denials on Requests for Relief – applicable if the IRS rejected your request for a payment plan, settlement, or other relief option.
• Trust Fund Recovery Penalty – assessed against individuals for a business’s unpaid payroll taxes.

Often, you get alerted about your right to appeal in an IRS letter or notice like the LT1058, which notifies you of the IRS’s intent to seize your assets, but not always – in some cases, you have appeal rights even if you haven’t received a notice. 

That’s why an attorney consultation is critical if you’re facing tax problems and aren’t sure of the options. 

IRS Appeals: Leverage Our Experience for Your Case

Our tax attorneys have successfully helped clients navigate the full range of IRS appeals. Here are the types of cases we can handle – let our experience drive the results you need:

Collection Due Process (CDP) hearings

Stop pending IRS collections like liens and levies by filing a CDP appeal. You can dispute the tax due if you haven’t had a chance to do so already, fight the proposed collection action, and apply for a payment plan or resolution on your tax debt. If you miss the deadline, we can help you with an equivalent appeal.

Let our attorneys represent you through the process and appeal the hearing results if needed, but act now – you only have 30 days from the date the IRS sent the final levy request.

Collection Appeals Program (CAP)

Appeal decisions concerning the rejection, modification, or termination of installment agreements. A CAP appeal also temporarily halts IRS collection actions until the appeal is settled. This appeal process is usually pretty fast and available in a lot more situations than a CDP, but you’ve only got one chance – you can’t appeal if you disagree with the CAP outcome.

That’s why experienced representation is critical – if you want to succeed, you’ll need to hit very tight deadlines and make a strong argument. 

Tax Lien Appeals

The IRS must notify you within five days of filing a tax lien, and once you get that notice, you have a few different appeal options. Let our team help you plot the right path forward to protect yourself from the financial effects of a tax lien attaching to your personal or business assets.

Tax Levy Appeals

IRS levies also bring a few different appeal options depending on the type of levy, whether it’s proposed or already in place, and the notices you’ve received. Levies are the most damaging IRS collection tool, and if you’re facing or currently dealing with one, you need help now. 

We’ll help you decide on the best appeals strategy to protect your assets and resolve the tax debt that led to the levy.

Installment Agreement Rejections, Terminations, or Modifications

You have appeal rights for most decisions that the IRS makes about Installment Agreements – whether the agency has rejected your request, terminated an existing agreement, or proposed unwanted changes. You need to exercise those appeal rights if you want to make monthly payments on your tax debt. 

When you contact us, we’ll build the case to get the IRS to change its decision.

Appealing Rejected Offer in Compromise Applications

Getting denied for an offer in compromise is devastating – especially after you’ve put in all that time and sent in a down payment – but it’s not the end of the road. You have the right to appeal, and if your appeal is successful, the IRS will accept your offer and apply your down payment to it. Also, filing an appeal will stop collections, which buys you a bit more time. 

Let us help. Whether you filed the request on your own or worked with another tax pro, we can take over from here and help you get the relief you need.

Penalty Abatement Denial Appeals

The IRS often says “no” to requests for penalty abatement – in many cases, that happens if you apply based on reasonable cause or statutory exception and your written explanation doesn’t convince the IRS to give you relief. That can be devastating, especially if you’re dealing with high-cost penalties like accuracy-related penalties, civil fraud penalties, or FBAR penalties.

Our experience means we know what the IRS wants to hear and how to reframe arguments that spur action. 

Innocent Spouse Relief Appeals

You have the right to appeal your request for Innocent Spouse Relief if the IRS denies your application or if they don’t respond within six months. And in both cases, you need representation from an experienced tax professional who understands the ins and outs of this type of IRS relief. 

We’ve helped countless clients qualify for innocent spouse with a strong application or through the appeals process – let us help you.

Risks of Not Exercising Your Appeal Rights

Not taking advantage of your appeal rights means losing your best tool for challenging the IRS, but that’s not the only risk. Here’s what can happen if you don’t appeal when you disagree with the IRS:

• Collection actions (wage garnishments, bank levies, etc) move forward – and then, they’re much harder to stop. 
• Tax assessments or penalties get finalized – and then, your only option may be to pay and request a refund. 
• Installment agreements get terminated – and then, the IRS will start to come after you for the full balance. 
• Relief options get denied – and then, your options narrow, whether you originally applied for an offer in compromise, innocent spouse, or another type of relief. 

Most appeals cases escalate due to missed deadlines – and typically that occurs when the taxpayer ignores the situation, so the IRS moves forward. Don’t let fear or procrastination make your tax problems worse; get an attorney involved. 

When to Hire a Tax Professional for an Appeal 

An experienced tax professional is critical during the appeals process. The tax matters that provide appeal rights are complicated, and simply deciding whether or not to appeal, let alone how to appeal, requires the knowledge of a tax professional. 

Here are big signs you should reach out to a tax attorney:

• The IRS is threatening to take action – seize assets, terminate a payment plan, etc.
• You have upcoming deadlines, and you don’t understand what they mean or what you need to do before they expire.

• There’s a significant amount of money at issue.
• The IRS rejected tax relief that you really need, like a settlement on an unaffordable tax bill or relief from a spouse’s tax debt.

Not sure? Reach out for a consultation to get a sense of how an attorney can help and their experience with your type of concern. 

How The W Tax Group Helps With IRS Tax Appeals 

Our tax team at The W Tax Group includes a variety of tax professionals, including attorneys, with experience handling IRS appeals. We understand when and how to use the appeals process to our clients’ advantage. 

Case evaluation – detailed examination of your situation.
Strategy – the best path forward based on your situation, driven by our experience.
Immediate action – appealing before the deadline; securing collection holds.
Negotiation and implementation – filing appeals, drafting arguments, and managing the case.
Follow-up – requests for more information from the IRS or additional appeals.
Resolution – after appeals, resolving any remaining tax debt, penalties, or problems.

Through every step of our process, we communicate with you so you know exactly what’s happening.

IRS Tax Appeals FAQs 

How long do I have to file an appeal? 

It depends on what you’re appealing and the method you’re using – often 30 days, but sometimes only a few business days. The letter or notice the IRS sends you should tell you how much time you have. 

How long does the appeals process take? 

It varies – while a CAP may be pretty quick, CDP hearings take a bit longer, and some appeals can take six or more months from filing to resolution. 

What’s the difference between a CDP hearing and the CAP? 

The main differences between the CAP and a CDP hearing are that the CAP is usually faster and available in more situations. Both options can temporarily stop certain IRS collection actions, but only the CDP offers additional appeal rights if you disagree. 

Can I represent myself during an IRS appeal? 

You can represent yourself, and it only make sense to do so in simple tax disputes or those involving relatively small amounts of money. You need professional representation for complex or large cases. 

Will filing an appeal stop an IRS collection enforcement action? 

Filing an appeal may temporarily stop IRS collection actions in certain cases. If you file a CDP hearing appeal, the IRS is usually prohibited from levying your property until the hearing is over. If you file an appeal through the CAP, then the IRS typically halts collection actions until the appeal is resolved.

Why The W Tax Group? Get Our Help Today

If you want to appeal an IRS decision, you’ve come to the right place. Here’s why you need our team on your side:

• Focused on tax resolution – This is all we do, and you need our specialized services.
• Experienced with all types of appeals – Whatever you’re facing, we’ve been there.
• Led by attorneys – Big problems require top-level expertise, and we’ve got that.
• Strong communication – We break everything down so you know what’s happening.
• Committed to success – our reviews speak for themselves; we get results for clients.

Contact us to schedule a free consultation and obtain a better understanding of your appeal rights before you miss an important deadline.