IRS Appeals And Tax Protest Hearing Attorneys
Receiving a letter from the Internal Revenue Service (IRS) with a large tax assessment causes concern for any business owner. The government gives taxpayers a short window to challenge these findings. This must happen before the debt becomes final. If you miss the deadline to file a protest, you must pay the disputed amount first and sue for a refund later.
Our attorneys at Blazier, Christensen, Browder & Virr, P.C., guide Austin residents and businesses through federal and state tax appeals. Our legal team analyzes your Revenue Agent Report (RAR) or audit findings to find errors. We build a factual case to challenge the assessment. Our attorneys manage communication with tax authorities so you can focus on your business.
The IRS Independent Office Of Appeals Process
Taxpayers who disagree with an audit can request a review by the IRS Independent Office of Appeals. This appeal provides a chance to resolve the tax dispute without filing a U.S. Tax Court petition. The appeals office operates independently of the examination division. The officer reviewing your case takes a fresh look at the facts and the law.
If the agency issues a 30-day letter, you must submit a formal protest letter within that time frame. Your submission must meet strict requirements. It must detail the specific adjustments you dispute and the law backing your position. If you fail to draft a complete protest letter, the IRS may dismiss your appeal.
Collection Due Process And Equivalent Hearings
When the government issues a notice of intent to levy, taxpayers can request a hearing to propose other payment methods. You secure a Collection Due Process (CDP) hearing by submitting IRS Form 12153 within 30 days. If you miss the 30-day deadline but file within a year, you may request an Equivalent Hearing. Both paths allow you to present your case to an officer. They offer different legal rights.
A CDP hearing provides several advantages for taxpayers facing collection efforts:
- Halting collection actions: The agency must pause most levies and garnishments while the CDP process is pending.
- Proposing other resolutions: Settlement talks during the hearing allow you to suggest installment agreements or offers in compromise.
- Seeking penalty abatement: You can present arguments to remove failure-to-pay or failure-to-file penalties.
- Preserving judicial review: A CDP decision allows you to appeal to the Tax Court if you disagree with the outcome.
These benefits help you manage your tax debt while protecting your assets. An Equivalent Hearing allows for similar talks but removes your right to challenge the decision in federal court.
Texas Comptroller Protest Procedures
State tax authorities enforce strict deadlines for sales and franchise tax audits. If you disagree with a state assessment, you must file a request within 60 days. The Texas Comptroller hearing process begins with an informal conference. You can present evidence to the auditor and their supervisor. This setting allows businesses to resolve exempt sales issues without a lawsuit. If the conference fails to resolve the issue, the case moves to a formal hearing before a judge. Managing these procedures requires a deep understanding of the Texas Tax Code.
Timelines And Strategies For Resolving Tax Disputes
Every phase of a tax dispute operates on a strict timeline. If you miss a deadline by one day, you lose your right to appeal without paying the full balance first. An Austin IRS lawyer finds the statutes of limitations that apply to your notice. Our team evaluates your finances and the government’s evidence to find the best path forward. Sometimes, the strategy involves pointing out a mistake in tax law. Other cases rely on proving financial hardship through the Collection Appeals Program.
Our legal team at Blazier, Christensen, Browder & Virr, P.C., understands the pressure of an audit. We review every line of your tax return and the government’s proposed changes to identify discrepancies. Our attorneys prepare the necessary documentation to support your claims and represent you during conferences with tax officers. We work to minimize your tax liability and resolve disputes efficiently.
Contact Our Tax Dispute Attorneys Today
Do not let a tax assessment damage your financial standing. Hire an attorney to evaluate your options and protect your rights during the appeal. Schedule a consultation with Blazier, Christensen, Browder & Virr, P.C., by calling 512-361-2268 today.