An Appeals hearing is an opportunity for an independent impartial review of an auditing agent’s report, should you disagree with the Agent’s finding. The purpose of the Appeals division at both the IRS and the FTB is to settle tax disagreements without having to go to Courts and a formal trial.
After completion of your audit, there may be some changes to your tax liability that you disagree with or issues that our team cannot resolve with the auditing agent. In cases where genuine issues remain in dispute, we recommend to all our clients to use the appeals process. In our experience, Appeals hearing officers possess a greater degree of flexibility and understanding of tax law allowing taxpayers an opportunity to seek greater tax relief. If you do not reach agreement with the Appeals or Settlement Officer, you may appeal certain actions through the courts.
The following is typically how the appeals process works:
(1) The first step in appealing a finding by the audit agent is to request a meeting with the auditing agent's supervisor
(2) If after meeting the auditing agent's supervisor, an agreement still can't be reached, our office can request a conference with an Appeals Officer. The IRS and the FTB's appeals division will then hear arguments from the Auditor as well as from members of my firm before issuing a decision.
Our firm is also capable of appealing a variety of tax issues, these include:
(1) Trust Fund recovery Penalty
(2) Offers in Compromise
(3) Employment Tax Adjustments
(7) Denials or terminations of Installment Agreements
(8) Denials of Abatement of Interest