Internal Revenue Disputes

If you’ve ever heard of someone formally contesting the taxes they owe to the IRS, it is called an internal revenue dispute. You may also hear this referred to, more officially, as an appeal.  The IRS defines this by stating, “When taxpayers disagree with the IRS’s decision on their tax situation, they can submit a written request to have the IRS Independent Office of Appeals review the decision. The goal of Appeals is to resolve tax disputes outside of the courtroom in a way that is fair and impartial and encourages voluntary compliance with tax law. This office is separate from the rest of the IRS in order to ensure its impartiality.”

How Does Someone File An IRS Dispute?

You can’t simply choose to dispute the IRS because you choose to do so.  The IRS says one can dispute the IRS if a person:

1. Received a letter from the IRS explaining their right to appeal the IRS’s decision

Imagine you open your mailbox and find a letter from the IRS stating that your tax return has been audited and adjustments have been made, increasing the amount you owe. The letter also explains that you have the right to appeal this decision. At this point, you can choose to challenge the IRS’s findings by requesting an appeal. This ensures you’re not simply stuck with the IRS’s first determination, but instead can have your case reviewed by the Independent Office of Appeals, which is designed to be impartial.

2. Disagree with the IRS’s decision

Suppose the IRS has denied deductions you claimed for business expenses, saying they were personal and not allowable. You know that you kept receipts, records, and can justify that the expenses were directly related to your business operations. Because you disagree with the IRS’s decision, you can formally dispute it. By filing an appeal, you present your evidence and reasoning to a neutral appeals officer, giving you another chance to prove that your deductions are legitimate.

3. Haven’t signed the IRS agreement form sent to them

Let’s say the IRS conducted an audit and sent you a Form 870, “Consent to Proposed Tax Adjustment,” which essentially means they want you to agree to pay additional taxes. If you believe the proposed changes are incorrect and you do not sign this agreement, you are not forced to accept the IRS’s assessment. By withholding your signature, you preserve your right to appeal and challenge the proposed tax liability. This allows you to argue your case before the Independent Office of Appeals instead of being automatically bound by the IRS’s determination.

IRS Dispute Attorney in Washington, DC & Maryland

When you’re up against the IRS, having the right advocate can make all the difference. Lead Tax Attorney Michael Lapidus, LL.M. in taxation from Georgetown University Law Center, is licensed in DC, Maryland, and Pennsylvania, and is experienced in representing taxpayers before the IRS and state tax authorities. He has also worked in the international tax department of a major accounting firm, giving him unique insight into complex tax issues. 

Whether you’re facing an audit, penalties, back taxes, or another IRS dispute, Michael will work tirelessly to protect your interests with the goal of minimizing your financial burden. Don’t navigate the IRS alone: call The Lapidus Law Firm today at 202-785-5111 for trusted representation and peace of mind.

 

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