Appealing an IRS Audit


A person can challenge IRS audit results by filing a tax appeal that will be reviewed by the IRS Independent Office of Appeals, which resolves tax audit and tax investigation disputes in an impartial manner.

A tax appeal may be warranted if:

  • You received a letter from the IRS explaining your right to appeal the IRS’s decision
  • You do not agree with the IRS’s decision
  • You are not signing an agreement form sent to you

The IRS provides the following consideration points when deciding if you should appeal the audit results:

  • IRS made an incorrect decision based on a misinterpretation of the law
  • IRS did not properly apply the law due to a misunderstanding of the facts
  • IRS is taking inappropriate collection action against you or your offer in compromise was denied and you disagree with that decision
  • Facts used by the IRS are incorrect. You should have organized records or other evidence to support your position

All taxpayers are entitled to have legal representation at any stage of an audit, including during the appeal.

A Kugelman Law tax appeals attorney will understand how to present to the appeals officer the relevant issues and identify misapplications of tax law.

If you appeal to the Office of Appeals and if they side with the auditor, you can still petition the U.S. Tax Court so you should remember that as a taxpayer you have options to challenge the IRS audit results.

Consequences of Not Making a Tax Appeal

Appealing an audit result is the most efficient way to challenge the audit. Otherwise, you will have to proceed with litigation in U.S. Tax Court to prevent the proposed tax from becoming legally owed.

The Kugelman Law tax appeals lawyers will:

  • Investigate the circumstances regarding the audit and relevant tax items.
  • Request all available IRS files related to the audit to ensure the auditor met administrative requirements.
  • Review, organize and obtain additional documentation that supports your tax return.
  • Advise you of any issues that we believe you are unlikely to prevail.
  • Prepare and submit letters to appeals regarding the relevant issues.
  • Advocate on your behalf with the appeals officer
  • Answer any legal questions you may have about the process

IRS audits often result in unfair conclusions when auditors disregard relevant documentation or misapply tax law. Kugelman Law attorneys can ascertain if an auditor has made a significant mistake during your tax audit, so it is important to understand that the auditor does not have the final word.

Instead, a taxpayer should appeal the audit results. Our team will present the most compelling case to the IRS Office of Appeals to demonstrate the audit findings were incorrect.

Kugelman Law Tax Appeals Lawyers

The Kugelman Law team is comprised of veteran lawyers with years of IRS and U.S. Tax Court experience resolving tax appeals disputes.

We strive to effectively and efficiently resolve each client’s tax issue – no matter the size or complexity.

The attorneys at Kugelman Law have experience helping clients throughout the countryt with tax appeals so please contact us today for a consultation.

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