Washington, DC tax counsel · Nationwide IRS representation
Washington, DC IRS Appeals representation.
The firm has an office at 1629 K Street NW, Suite 300 in Washington, DC and represents individuals and closely held businesses in disputes before the IRS Independent Office of Appeals.
Each matter begins with the IRS notice that offers an appeal, the issues in dispute, and the deadline printed on that notice.
Start with the Independent Office of Appeals.
The IRS Independent Office of Appeals is the IRS function that resolves tax disputes without litigation, in a way that is fair and impartial to the government and to the taxpayer.
An appeal is available only when the IRS notice or letter offers that opportunity and the request follows the instructions and deadline in that document. IRS Publication 5 explains how to request Appeals review and what a written protest must include when one is required.
Official source: IRS Independent Office of Appeals
Official source: IRS Publication 5
The work
How the firm approaches an IRS appeal.
Read the notice
Identify the proposed change or collection action, the stated appeal opportunity, the response deadline, and the instructions for requesting review.
Build the protest
State the adjustments or actions in dispute, the facts, and the legal position. IRS Publication 5 explains when a written protest is required and what it must contain.
Prepare the conference
Organize the record, prepare the taxpayer for a conference, and attend an authorized conference when the matter requires it.
Address what follows
Review any Appeals determination and the remaining administrative or court options based on the actual letter and deadline.
Which notices offer an appeal.
The IRS publishes a list of letters and notices that offer an appeal opportunity. IRS Letter 525 is one examination letter that may enclose a report and explain how to request Appeals review. Collection notices can offer a different hearing path, including a Collection Due Process hearing after a final levy notice such as LT11 or Letter 1058.
A later IRS Letter 3219, Notice of Deficiency states a deadline to petition the United States Tax Court. That court deadline is not the same as an Appeals conference deadline. Read the current notice before choosing a path.
Official source: Letters and notices offering an appeal opportunity
Official source: Requesting an appeal
Official source: Collection Due Process FAQs
Questions
Common questions.
What is the IRS Independent Office of Appeals?
The IRS Independent Office of Appeals is the IRS function that resolves tax disputes without litigation, in a way that is fair and impartial to the government and to the taxpayer. Law Office of Alexander Powell, PLLC has an office at 1629 K Street NW, Suite 300 in Washington, DC and represents individuals and closely held businesses in disputes before Appeals.
When can a taxpayer request IRS Appeals review?
An appeal is available only when the IRS notice or letter offers that opportunity and the request follows the instructions and deadline in that document. IRS Publication 5 explains how to request Appeals review and what a written protest must include when one is required. Before a case reaches Appeals, the IRS office that issued the notice considers the protest.
Is an IRS Appeals conference the same as a Tax Court case?
An Appeals conference is an administrative review inside the IRS. A later IRS Letter 3219, Notice of Deficiency, states a deadline to petition the United States Tax Court. That court deadline is not the same as an Appeals conference deadline. An Appeals request does not, by itself, create Tax Court jurisdiction. Read the current notice before choosing a path.
Which IRS letters offer an appeal opportunity?
The IRS publishes a list of letters and notices that offer an appeal opportunity. IRS Letter 525 is one examination letter that may enclose a report and explain how to request Appeals review. Collection notices can offer a different hearing path, including a Collection Due Process hearing after a final levy notice such as LT11 or Letter 1058.
Does requesting Appeals stop IRS collection?
An Appeals request does not, by itself, stop every collection action. Collection notices can offer a Collection Due Process hearing, which is a separate hearing path heard by Appeals. The date and instructions on the notice in hand control. Do not use this page to calculate that deadline.
What Appeals may do.
Before a case reaches Appeals, the IRS office that issued the notice considers the protest. If that office does not resolve the dispute, it forwards the case to Appeals. The actual next step depends on the written determination and any remaining deadline. An Appeals request does not, by itself, create Tax Court jurisdiction or stop every collection action.
If the matter is still an examination, start with IRS audit defense. If the IRS is collecting an assessed balance, start with IRS collections.
Related pages
Related IRS Appeals resources.
- Tax controversy attorney DCThe Washington, DC tax controversy path from IRS notice to Tax Court and D.C. OTR.
- IRS audit defenseReturn to the examination hub when the dispute still concerns an open or recently closed audit.
- U.S. Tax CourtA Notice of Deficiency states a Tax Court deadline. That path is separate from an Appeals conference.
- IRS collectionsRead how the firm approaches unpaid balances, liens, levies, and collection hearing rights.
- IRS Letter 525Review the examination report letter that may offer an Appeals opportunity.
- IRS Letter 3219A Notice of Deficiency states a Tax Court deadline. That path is separate from an Appeals conference.
- IRS Letter CheckLook up the code printed on a supported IRS letter.
- Practice areasReview the firm’s federal, District of Columbia, Maryland, and international-reporting scope.
A simple first step
Start with what you know.
Tell me what the IRS notice says you may appeal and the deadline shown. Send only a high-level summary. Documents can be reviewed later, if needed.
Start here