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.