If you disagree with the Internal Revenue Service regarding the amount of your tax liability or certain collection actions, you can appeal the decision to a local Office of Appeals, which operates independently from the IRS office that is taking action against you.
The Office of Appeals provides the only level of appeal within the IRS. Conferences with Office of Appeals personnel are held in an informal manner by correspondence, by telephone or in person. Many differences can be settled within this system without expensive, time-consuming court trials.
If you unreasonably fail to pursue the IRS appeals system, or if your case is intended primarily to cause delay or your position is frivolous, the tax court may impose a penalty of up to $25, 000. We will help you assure that your case has merit.
Appeal To The Court
If you and the IRS still disagree after the Office of Appeals conference, you may be entitled to take your case to the United States Tax Court, the United States Court of Federal Claims or the United States District Court. These courts are independent of the IRS.
Cranston lawyer Michael T Napolitano advocates for Rhode Island taxpayers defending complex taxation matters. Mr. Napolitano has extensive tax court experience, assisting businesses and individuals following an IRS audit or state audit.
We can assist you in filing an appeal or represent you if you face charges of tax fraud or tax evasion.
Because of the extensive resources the IRS has, tax litigation matters must be addressed by an experienced attorney who has a full understanding of tax laws and who knows how to deal with federal and state tax officials. Mr. Napolitano has practiced law since 1981. He attended a master’s in taxation program at Bryant College and earned an advanced master of laws degree (LL.M.) in taxation from Boston University.
Fast Track Mediation
The IRS offers fast track mediation services to help taxpayers resolve many disputes resulting from examinations, Offers in Compromise and trust fund recovery penalties.
Fast Track mediation offers an expedited process with a trained mediator in a neutral setting. If you don’t agree with any or all of the IRS findings, you have the right to request a conference with the manager of the person who issued the finding.
In order to avail yourself of the mediation process, all documentation to consider your case must be provided to compliance. On collection cases, you must be current with filing requirements and current with deposits.
You and the IRS representative must sign an agreement to mediate prior to attending the mediation session. The mediation process involves an appeals officer who is trained in mediation. You have the right to withdraw from the mediation process at anytime.
Contact us to schedule a free, no-obligation consultation with a Cranston tax litigation attorney who can provide you more information about tax litigation or fast track mediation.