Individual; usually local, fairly reasonable and looking to close cases;


  • Staffed by competent people;
  • Types of matters handled before appeals officers include:
  • Appeals of Final Notice of Attempt to Levy;
  • Appeals relating to Offer In Compromises;
  • Appeal of the Denial of a Penalty Abatement Request
  • Appeal of the filing of a Tax Lien;
  • Appeal offices may request additional information and may give a TIME DEADLINE;
  • Most officers are flexible with the deadline SO LONG AS YOU COMMUNICATE WITH THEM BEFORE THE DEADLINE IS UP!
  • Appeals are usually set by a telephone conference with the Appeals Officer.


  • Must become admitted to Practice in TAX COURT.
  • Ways in which a mother may end up in tax court:
  • Filing A Tax Court Petition after an Adverse Ruling from an appeals offices;
  • Filing A Tax Court Petition After an Assessment of taxes against a client.
  • Once a petition is filed, an attorney will be assigned to represent the IRS.
  • Contact the IRS attorney; open a dialogue; case may settle.
  • Eventually, a Pre-Trial Hearing Will Be Set (By Telephone Conference?)
  • If not resolved, then it will be set for trial.


    • Manual for employees of the IRS.
    • Has major Sections or Collections.
    • Sets forth whether an OIC Should be accepted and for how much.

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