IRS Tax Appeals

Before preparing a request for Appeals, select the appropriate appeal procedure. Sometimes the choice comes down to whether you want to retain the right to take your case to court. If you decide you want to present your dispute to Appeals, you will need to prepare a request for Appeals and mail it to the office that sent you the decision letter.

Collection Appeals Program (CAP)
Collection Appeals Program (CAP) is generally quick and available for a broad range of collection actions. However, you can’t go to court if you disagree with the Appeals decision.

Collection Due Process (CDP)
Collection Due Process (CDP) is available if you receive one of the following notices: a Notice of Levy and Notice of Your Right to a Hearing, a Final Notice – Notice of Intent to Levy and Notice of Your Right to A Hearing, a Notice of Levy on Your State Tax Refund – Notice of Your Right to a Hearing (Levy Notices), a Notice of Federal Tax Lien Filing and Your Right to a Hearing Under IRC 6320 (Lien Notice), and a Notice of Jeopardy Levy and Right of Appeal. If you disagree with the Appeals decision, you may be able to take your case to court.

Trust Fund Recovery Penalty (TFRP)
If you are a person responsible for withholding, accounting for, or depositing or paying specified taxes including non-resident alien (NRA) withholding and employment taxes, and willfully fail to do so, you can be held personally liable for a penalty equal to the full amount of the unpaid trust fund tax, plus interest. A responsible person for this purpose can be a sole proprietor, a partner, an owner or officer of a corporation, or an employee of any form of business. A trustee or agent with authority over the funds of the business can also be held responsible for the penalty.

Offer in Compromise – “Pay Pennies on the Dollar” (OIC)
An Offer in Compromise (OIC) is an agreement between you and the government that settles a tax liability for payment of less than the full amount owed.

Fix your tax problem with the help of an experienced tax attorney. Call Mitchell A. Port at (310) 559.5259.