After the Revenue Agent writes a final “Revenue Agent Report”, you have either 30 days or 60 days (depending on the type of tax return examination) within which to file a Protest to the IRS Office of Appeals. After that time expires, the next course of action is usually a Petition in the United States Tax Court, so the deadline for filing a Protest should be taken seriously.
A properly-prepared Protest not only sets forth the items of disagreement with the Revenue Agent, but also contains a detailed analysis of the legal basis for the taxpayer’s arguments disputing the findings of the Revenue Agent. Appeals Officers are frequently trained in tax law, and have access to IRS lawyers who can help them sift through the nuances of tax law, in order to decide whether the taxpayer’s arguments have strength, or any merit at all. It is very important to have an experienced tax lawyer on your side through this process.
David A. Sprecace has more than 23 years of experience preparing Protests to the IRS Office of Appeals, meeting with Appeals Officers, and proceeding to Tax Court if necessary. Call 303-454-8260 or email Dave at Dave@MyTaxLex.com to set up a phone consultation.