Collection Due Process Appeals

Individuals have the right to appeal any tax assessment or to challenge enforcement actions taken by the IRS. This includes appeals of the Trust Fund Recovery Penalty, federal tax liens or levies, or a Revenue Officer's rejection of an offer in compromise or installment agreement.

Brown, PC represents clients through every stage of the collection due process appeal, including:

  • Direct negotiations with the IRS Revenue Officer to reverse or amend his position
  • Filing with the IRS Appeals Office for a conference with an Appeals Officer, who has authority to overturn the Revenue Officer's ruling
  • Appealing a decision of the Appeals Office to U.S. District Court or beyond

Mr. Brown is familiar with the deadlines, procedures and requirements for each stage of appeals, and works proactively to prevent or negotiate tax obligations and penalties on the front end of tax disputes.

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