There are many procedural steps that can be involved in finalizing an IRS audit or collection matter to get the best available result. These steps may seem onerous, insurmountable or are totally unknown to a taxpayer who is not familiar with the tax system. There are usually multiple options available to both the taxpayer and the IRS to resolve tax matters. The Law Office of Stanton D. Goldberg is knowledgeable and experienced in IRS procedure and utilizes this knowledge to help its clients get the best available result for their tax case.
Understanding Federal Tax System Procedure
Briefly, the IRS consists of two primary field office functions/divisions, Examinations (Audit) and Collections. It is the people from these field offices that conduct the audits and are the “boots on the ground” for pursuing collection actions.
If you are not satisfied with or cannot resolve your examination matter or collection matter with the office or field representative that you are dealing with, there are procedures available to take your matter to the IRS Appeals Division for additional consideration. These appeal procedures are quite different depending upon whether you are appealing from an examination or collection action. Often, it is necessary for cases to be appealed to the IRS Appeals Division in order to get a better result for the taxpayer then has been reached with the field examination or collection office.
If you cannot reach a resolution of an audit during discussions with the IRS Appeals Division or if you did not had an opportunity to appeal your matter, but have received a Notice of Deficiency concerning an assessment of tax, you can continue to argue for a better or more appropriate solution for your case by filing a petition with the U.S. Tax Court.
Many IRS collection actions can be appealed to either prevent or reverse an IRS collection action. One of the most important collection appeal rights is the Right to a Collection Due Process Hearing. This is an extremely important collection procedure right that has been given to taxpayers under the Internal Revenue Code. A Collection Due Process Hearing can prevent IRS enforced collection action while an independent appeals officer reviews your collection case.
Taxpayers can represent themselves in matters before the IRS Appeals Division or the U.S. Tax Court, although this is not usually advised since the matters that reach these levels for consideration are often procedurally complex and require a detailed knowledge of the Internal Revenue Code to get the best result. Additionally, while CPAs and Enrolled Agents can represent taxpayers on other matters, only licensed attorneys and other people that have passed an examination and are admitted to practice before the U.S. Tax Court can file a petition to represent taxpayers before that Court.
The tax attorneys at the Law Office of Stanton D. Goldberg are experienced and knowledgeable in the law and procedural methods necessary to help their clients obtain the best result for their case.
The Law Office of Stanton D. Goldberg represents clients in Dallas, Collin, Rockwall, Tarrant, and Denton counties who are facing IRS business or income tax audits. Founder and principal, Stanton D. Goldberg is both a tax lawyer and a certified public accountant who deals with every tax matter as directly and proactively as possible.
Contacting Our Office
To discuss your IRS situation with an accomplished tax attorney, please call 972-960-2200 or contact us at our Dallas, Texas, law offices today. You can also contact us online.