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The Internal Revenue Service has an appeals system for taxpayers who do not  agree with the results of an examination of their tax returns or with other  adjustments to their tax liability.

In addition to examinations, many other things can be appealed, among them  are:

- Collection actions such as liens,  levies, seizures, installment agreement terminations, and rejected offers in  compromise – Penalties and interest – Employment tax adjustments and the  trust fund recovery penalty

The Appeals Office is separate from the IRS Office taking the action you  disagree with. The Appeals Office is the only level of administrative appeal  within the IRS. Conferences with Appeals Office personnel are held by  correspondence, by telephone or at a personal conference.

An Appeals Officer will review the strengths and weaknesses of the issues in  your case and give them a fresh look. Appeals will consider any just reason you  have for disagreeing, except for moral, religious, political, constitutional,  conscientious objection, or similar grounds.

Although a taxpayer’s right to appeal is guaranteed, the IRS imposes strict  requirements as to when a taxpayer’s request for appeal (sometimes called a “Tax Protest”) must be filed. The filing period for filing the Tax Protest is generally 30 days from the date of the IRS Notice identifying the agent’s  findings and offering to appeal these findings to the Appeals Office.

If you decide to do nothing or fail to timely file a Tax Protest and your case involves an examination of  your income, estate, gift, and certain excise taxes or penalties, you will  receive a formal Notice of Deficiency. The Notice of Deficiency allows you to  appeal the IRS’ findings to the Tax Court. If you do not go to the Tax Court,  you will have waived your rights to appeal the findings and the IRS will send  you a bill for the amount due.

If you decide to do nothing or fail to timely file a Tax Protest and your case involves a trust fund  recovery penalty, or certain employment tax liabilities, the IRS will send you a  bill for the penalty. If you do not appeal a denial of an offer in compromise or a denial of a penalty abatement request, the IRS will continue collection action.

Mr. Cotton is familiar with the IRS and knows how to present your appeal with  legal argument and tax authority. If you do not agree with the result of your  examination by the IRS and want to file an appeal, Call The Law Office of Richard B. Cotton NY - Top New York City Tax Lawyer at (212)  297-0275.

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