Your audit ended with the IRS taking a bad position.
You need to get to IRS Appeals, and the IRS auditor sent you a Letter 950
which, offered you two ways to get to IRS Appeals, both of which are
wrong. Why? Because if you go directly to IRS
Appeals, and are unsuccessful with Appeals, you will then receive a 90 Day
Letter which will be written by an IRS Appeals Officer. The professionals in the IRS Appeals
Division typically have 20 years of experience. Most of them are lawyers, and the rest are CPAs. Some of the lawyers have LL.Ms in tax
law.
By contrast,
the better approach is to refuse the IRS auditor’s offer of the two ways to go
to IRS Appeals. As a result, the
IRS auditor, who is unlikely to be a lawyer or CPA, who is likely to have 5
years of experience, will draft the 90 Day Letter. When you receive that letter you will be forced to file a
petition in the United Stated Tax Court. Then the IRS District Counsel will file a response within 60 days. However, once that occurs you will be
able to talk to IRS Counsel and confirm that your matter will be sent to the
IRS Appeals Division.
In our next
blog we’ll continue our discussion of why this second approach is the superior
way to get to the IRS Appeals Division.
Find out what Givner & Kaye can do for you. Contact us today. www.GivnerKaye.com (310) 207-8008
Continue reading “Part 2 Of 3: The Wrong Way To Get To IRS Appeals”
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