Many taxpayers hire CPAs or Enrolled Agents to handle their IRS problem cases. I guess they think that tax attorneys are too expensive or they fear the (often deserved) reputation of attorneys in general. But the IRS announcement of two new IRS appeals programs may cause you to think twice about who you hire to handle your Offer in Compromise or Trust Fund Recovery Penalty (TFRP) case.
The IRS has announced the formation of two new appeal programs. This is exciting news because it allows taxpayers more opportunities to be heard by high level, well trained IRS employees with considerable discretion. Unlike most field level IRS employees (especially those that work in call centers) IRS appeals personnel have considerable training and discretion when working on a taxpayer's case.
The truth is that IRS field level personnel can be very difficult. They don't have much authority to do much more than say "pay us yesterday." There are two types of IRS employees. Those that view themselves as problem solvers (rare) and those that see themselves are revenue generators (common.) The simple fact is that we have to use IRS Appeals quite commonly in a wide variety of situations. You can appeal just about any collection action taken by the IRS…..if you know how and what to do.
When you have tax disputes, one option you have to help solve this IRS Problem is to use your right to appeal a decision. Using IRS Appeals is a way to settle tax disputes without going to Tax Court. It is much more informal than an actual trial.
You're not happy with the decision from any IRS collection action, a collection appeals hearing is your right. It's simply a meeting where you and the IRS can find ways to settle the dispute.