by Fresh Start Tax | Jul 2, 2013 | Tax Levy and Wage Garnishments
There is a very specific process to stop an IRS wage garnishment.
As a former IRS agent I have issued thousands of bank levies and IRS wage garnishment’s and I can tell you firsthand there is only one way to go ahead and release any IRS wage levy garnishment.
First Things First, What is a IRS WAGE GARNISHMENT?
A IRS WAGE GARNISHMENT is a legal seizure of your property to satisfy a back tax debt.
Levies or garnishments are different from liens. A lien is a claim used as security for the tax debt, while a levy actually takes the property to satisfy the tax debt.
If you do not pay your taxes or make arrangements to settle your debt the IRS may seize and sell any type of real or personal property that you own or have an interest in.
What IRS has the right to do.
IRS can seize and sell property that you hold such as your car, boat, or house or IRS
could levy property that is yours but is held by someone else such as your wages, retirement accounts, dividends, bank accounts, licenses, rental income, accounts receivables, the cash loan value of your life insurance, or commissions.
These three requirements are must be met for IRS to levy wages:
- They assessed the tax and sent you a Notice and Demand for Payment;
- You neglected or refused to pay the tax; and
- They sent you a Final Notice of Intent to Levy and Notice of Your Right to A Hearing (levy notice) at least 30 days before the levy.
IRS may give you this notice in person, leave it at your home or your usual place of business, or send it to your last known address by certified or registered mail, return receipt requested.
If you have a hardship situation, contact us immediately.
A levy/garnishment release does not mean you are exempt from paying the balance.
The IRS will work with you to establish payment plans or take other steps to help you pay off the balance.See below.
Important Note to Employers who receive IRS Wage Garnishment on Employees
Employers generally have at least one full pay period after receiving a Form 668-W, Notice of Levy on Wages, Salary and Other Income before they are required to send any funds from their employee’s wages.
You can always ask the IRS manager to review the case.
You may ask an IRS manager to review your case, or you may request a Collection Due Process hearing with the Office of Appeals by filing a request for a Collection Due Process hearing with the IRS office listed on your notice.
Option of File an Appeal
You must file your request within 30 days of the date on your notice. Some of the issues you may discuss include:
1. You paid all you owed before we sent the levy notice,
2. IRS assessed the tax and sent the levy notice when you were in bankruptcy, and subject to the automatic stay during bankruptcy,
3. IRS made a procedural error in an assessment,
The time to collect the tax (called the statute of limitations) expired before we sent the levy notice,
4. You did not have an opportunity to dispute the assessed liability,
5. You wish to discuss the collection options, or
6. You wish to make a spousal defense.
At the conclusion of your hearing, the Office of Appeals will issue a determination. You will have 30 days after the determination date to bring a suit to contest the determination. Refer to Publication 1660 (PDF), for more information.
If your property is levied, garnished or seized, contact the employee who took the action. You also may ask the manager to review your case. If the matter is still unresolved, the manager can explain your rights to appeal to the Office of Appeals.
How to Stop the IRS Wage Garnishment
To stop the IRS wage garnishment you will need to give the Internal Revenue Service a current financial statement and that will be need to given on form 433f, you can find that form on our website.
Make sure you fill out an honest and accurate financial statement because IRS will verify everything that is on that financial statement along with all documentation.
IRS will also request the last 3 to 6 months worth of bank statements and your last pay stub.
IRS will then conduct a national and regional standards test and compare them against your financial statement. The purpose for this, IRS wants to make sure you’re living within your means.
Once IRS compares your financial statement against the standards, IRS will suggest to you that your case is either eligible for a economic tax hardship which is called currently noncollectable or IRS will demand an installment payment agreement, or IRS will recommend to you that you are an offer in compromise candidate.
Once IRS has your current financial statement and makes a determination on your case they will release your wage levy garnishment as a general rule that same day.
The Key to getting a Wage Garnishment Release
The key to get immediate release of an IRS wage garnishment is to call the Internal Revenue Service and be ready to fax the financial statement with all verifying information to the agent on the phone and have IRS make a determination right then and there.
Contact us today for a free initial tax consultation and see how we can stop your IRS wage garnishment and settle your tax case.
Do not be bullied by the Internal Revenue Service.
How to STOP a IRS Wage Garnishment, Former IRS Agent Explains
by Fresh Start Tax | Jul 2, 2013 | Tax Help
We are the Affordable Professional Tax Local Tax Firm that specializes in Individual, Business and Corporate Tax Audits.
If you are going to undergo an IRS tax audit contact us today for free initial tax consultation and speak directly to former IRS agents and managers who worked countless numbers of tax audits as former IRS employees.We know the system.
Who better to know the IRS audit procedures and policies than former agents and managers. As a result of our years of experience we know the best tax strategies, best tax solutions and best settlement policies to help you through your IRS audit.
We also have on staff a former IRS appeal agent of 25 years who can help cover any issues we feel that the Internal Revenue Service is treating our clients in an unfair manner.
Contact us today for an initial tax consultation. We handle all individual, business, and corporate tax audits.
We have over 206 years of professional tax experience and we are A+ rated by the Better Business Bureau.
We have been practicing right here in South Florida since 1982.
Common Question asked of IRS Tax Audits for Business or Corporations
- Where will the audit be held?
It depends on the type of audit being conducted. There are two types;
1. Audits by Mail/Correspondence Audit: Some audits are conducted entirely by mail. If the audit is conducted by mail, you will receive a letter from the IRS asking for additional information about certain items shown on the tax return such as income, expenses, and itemized deductions.
2. In-Person Audits are audits conducted either at a local IRS office or at your business location.
- Can you request the audit be conducted at the IRS office instead of at your place of business?
If the audit has been scheduled to be conducted at your location, it will generally be conducted where the books and records are located. Requests to transfer the audit to another location, including an IRS office, will be considered but may not be granted. Treasury Regulation 301.7605-1(e), Time and place of audit, discusses the items considered when a request for a change in location is made.
- Can the audit be transferred to another IRS office?
You can request a transfer of an audit if you have moved. Several factors will be considered such as your current location, the location of the business and where the books and records are maintained.
If the audit is by correspondence, you can request a face-to-face audit because the books and records may be too voluminous to mail.
- How long should the records related to a business or other long-term asset be kept?
In the case of an asset, records related to the asset should generally be kept for as long as you have the asset plus three years. If the asset was exchanged, the basis for the new asset may include the exchanged asset so the records for both assets will need to be retained until the new asset is disposed plus three years from the file date of the tax return for the year of disposition.
- How long should payroll records be kept?
In general, payroll records should be kept for six years with a review of the file to see if any items relating to current employees should be retained with current records.
- After an auditor completes the audit, will the case be reviewed to ensure the audit results are correct?
All cases may be reviewed by the auditor’s manager either during the audit or upon completion. If errors are noted by the manager, the auditor will contact you to advise you about the proposed correction and what impact this may have on the amount of tax due.
- How far back can the IRS go to audit my return?
Generally, the IRS can include returns filed within the last three years in an audit. Additional years can be added if a substantial error is identified. Generally, if a substantial error is identified, the IRS will not go back more than the last six years.
The IRS tries to audit tax returns as soon as possible after they are filed. Accordingly most audits will be of returns filed within the last two years.
If an audit is for an older year, you may be requested to extend the statute of limitations for assessment of your tax return. The statute of limitations limits the time allowed to assess additional tax. The statute of limitations is generally three years after a return is due or was filed, whichever is later. There is also a statute of limitations for making refunds.
If the audit is not resolved and the statute of limitations date is nearing, you may be asked to extend the statute of limitations date.
This will allow you additional time to provide further documentation to support your position, request an appeal if you do not agree with the audit results, or to claim a tax refund or credit.
It also allows the IRS time to complete the audit and provides time to process the audit results.
You do not have to agree to extend the statute of limitations date. However, if you do not agree, the examiner will be forced to make a determination based upon the information they currently have.
Therefore, the examiner may not be able to consider additional adjustments, such as expenses, that could lower the amount of tax due.
Contact us today for a free initial tax consultation and find out your options for IRS tax audits. You will speak directly to former IRS agents and managers who have over 60 years of working tax audits for the Internal Revenue Service.
Tax Audits – Business, Corporate – IRS & State – Miami, Ft.Lauderdale, West Palm Beach
by Fresh Start Tax | Jul 2, 2013 | Tax Help
There are many IRS Appeal Processes.
At almost any stage that you have an open case with the IRS there can be an appeal tool that can help you out of a jam.
We are comprised of former IRS agents and managers who have over 60 years of combined IRS experience in the local, district, and regional tax offices of the Internal Revenue Service.
Contact us today for free initial tax consultation and let’s see if we can help resolve your situation.
Our firm has over 206 years professional tax experience and we are A+ rated by the Better Business Bureau.
We are the Affordable Tax Firm.
Different types of IRS Appeals
IRS Letter 11 – This Final Notice of Intent to Levy and Notice of Your Right to a Hearing
This letter is to notify you of your unpaid taxes and that the Service intends to levy to collect the amount owed. The letter and referenced publications explain how to request an appeal if you do not agree. You need to file a Form 12153, Request for A Collection Due Process Hearing and send it to the address shown on your levy notice within 30 days from the date of the letter in order to appeal the proposed action with the Office of Appeals.
Letter 525 – General 30 Day Letter
You will get this letter with a computation report of proposed adjustments to your tax return. It outlines your options if you do not agree with the proposed adjustments. If you agree with the adjustment, you sign and return the agreement form.
If you do not agree, you can submit a request for appeal to the office/individual that sent you the letter. The letter contains information and lists IRS publications on how to file an appeal/protest.
You need to file your protest within 30 days from the date of this letter in order to appeal the proposed adjustments with the Office of Appeals.
Letter 531 – Notice of Deficiency
You will get this letter if you owe additional tax or other amounts for the tax year(s) listed in the letter. The letter explains how to dispute the adjustments if you do not agree.
If you want to dispute the adjustments without payment, you will have 90 days from the notice date to file a petition with the Tax Court.
Letter 692 – Request for Consideration of Additional Findings
You will get this letter with a computation report of proposed adjustments to your tax return. It outlines your options if you do not agree with the proposed adjustments. If you agree with the adjustment, you sign and return the agreement form.
If you do not agree, you can submit a request for appeal to the office/individual that sent you the letter. The letter contains information and lists IRS publications on how to file an appeal/protest.
You need to file your protest within 15 days from the date of this letter in order to appeal the proposed adjustments with the Office of Appeals.
Letter 915 – Letter to Transmit Examination Report
This letter explains adjustments in amount of tax. The letter explains that if you agree with the adjustment, you sign and return the agreement form.
If you do not agree, you can submit a request for appeal/protest to the office/individual that sent you the letter. The letter or referenced publications explain how to file a protest. You need to file your protest within 30 days from the date of this letter in order to appeal the proposed adjustments with the Office of Appeals.
Letter 950 – 30 Day Letter-Straight Deficiency or Over-Assessment
This letter is used for un-agreed, straight deficiency, straight over assessment or mixed deficiency and over assessment cases. This letter may be used for various types of tax. If you agree with the adjustment, you sign and return the agreement form.
If you do not agree, you can submit a request for appeal to the office or individual that sent you the letter. The letter contains information and lists IRS publications on how to file a protest. You need to file your protest within 30 days from the date of this letter in order to appeal the proposed adjustments with the Office of Appeals.
Letter 1058 – Final Notice Reply Within 30 Days
This letter is to notify you of your unpaid taxes and that the Service intends to levy to collect the amount owed. The letter and referenced publications explain how to request an appeal if you do not agree. You need to file a Form 12153, Request for A Collection Due Process Hearing and send it to the address shown on your levy notice within 30 days from the date of the letter in order to appeal the action with the Office of Appeals.
Letter 1085 – 30-Day Letter Proposed 6020(b) Assessment
This letter is to notify you of your unpaid taxes and that the Service intends to levy to collect the amount owed.
The letter and referenced publications explain how to request an appeal if you do not agree. You need to file a Form 12153, Request for A Collection Due Process Hearing and send it to the address shown on your levy notice within 30 days from the date of the letter in order to appeal the action with the Office of Appeals.
Letter 1153 – Trust Funds Recovery Penalty Letter
This letter explains that the IRS’s efforts to collect the federal employment or excise taxes due from the business named on the letter have not resulted in full payment of the liability. Therefore, the IRS proposes to assess a penalty against you.
If you agree with this penalty for each tax period shown, you are asked to sign Part 1 of the enclosed Form 2751 and return it to the person/office that sent you the letter. If you do not agree you can submit a request for appeal to the office/individual that sent you the letter. The letter contains information and lists IRS publications on how to file an appeal/protest. You need to file your protest within 60 days from the date of the letter in order to appeal this decision with the Office of Appeals.
Letter 3016 – IRC Section 6015 Preliminary Determination Letter (30 Day)
This is a preliminary letter giving you 30 days to appeal the determination for innocent spouse relief under IRC Section 6015.
The letter explains that if you do not agree with the determination you can submit a request for appeal/protest to the office/individual that sent you the letter. The letter explains how you file a protest. You need to file your protest within 30 days from the date of this letter in order to appeal the proposed adjustments with the Office of Appeals.
Letter 3391 – 30-Day Non-filer Letter
This letter advises you the IRS believes you are liable for filing tax returns for the periods identified in the letter. It includes a report giving you a computation of the proposed adjustments to your tax return and explains the adjustments. The letter explains that if you agree with the adjustments, you sign and return the agreement form.
If you do not agree, you can submit a request for appeal/protest to the office/individual that sent you the letter. The letter or referenced publications explain how to file a protest. You need to file your protest within 30 days from the date of this letter in order to appeal the proposed adjustments with the Office of Appeals.
Letter 3727 – 30-Day Letter Notifying Taxpayer No Change to Original Report Disallowing EIC Based on Failure to Meet Residency Test for Children Claimed
This letter explains why the IRS will not allow your earned income credit (EIC). The letter explains that if you agree with the adjustment, you sign and return the agreement form.
If you do not agree, you can submit a request for appeal/protest to the office/individual that sent you the letter. The letter or referenced publication explains how to file a protest. You need to file your protest within 30 days from the date of this letter in order to appeal the proposed adjustments with the Office of Appeals.
Letter 3728 – 30-Day Letter Notifying Taxpayer No Change to Original Report Partially Disallowing EIC Based on Failure to Meet Residency Test for 1 Child
This letter explains why the IRS can only give you part of your earned income credit (EIC). The letter explains that if you agree with the adjustment, you sign and return the agreement form.
If you do not agree, you can submit a request for appeal/protest to the office/individual that sent you the letter. The letter or referenced publication explains how to file a protest. You need to file your protest within 30 days from the date of this letter in order to appeal the proposed adjustments with the Office of Appeals.
Letter 3172 – Notice of Federal Tax Lien Filing and Your Rights to a Hearing under IRC 6320
This letter is to notify you the IRS filed a notice of tax lien for the unpaid taxes. If you do not agree you can request appeals consideration within 30 days from the date of the letter. The letter and publications explain how to request a hearing from Appeals.
You need to file a Form 12153, Request for A Collection Due Process Hearing and send it to the address shown on your lien notice within 30 days from the date of the letter in order to appeal the action with the Office of Appeals.
Notices
CP 90 – Final Notice of Intent to Levy
CP 90 notifies you of your unpaid taxes and that the IRS intends to levy to collect the amount owed.
This notice and referenced publications explain how to request an appeal if you do not agree. You need to file a Form 12153, Request for A Collection Due Process Hearing and send it to the address shown on your levy notice within 30 days from the date of the letter in order to appeal the action with the Office of Appeals.
CP 92 – Notice of Levy upon Your State Tax Refund
CP 92 notifies you that the IRS levied your state tax refund to pay your unpaid federal taxes. This notice and referenced publications explain how to request an appeal if you do not agree.
You need to file a Form 12153, Request for A Collection Due Process Hearing and send it to the address shown on your levy notice within 30 days from the date of the letter in order to appeal the action with the Office of Appeals.
CP 242 – Notice of Levy upon Your State Tax Refund
CP 242 notifies you that the IRS levied your state tax refund to pay your unpaid federal tax.
This notice and referenced publications explain how to request an appeal if you do not agree. You need to file a Form 12153, Request for A Collection Due Process Hearing and send it to the address shown on your levy notice within 30 days from the date of the letter in order to appeal the action with the Office of Appeals.
CP 523 – IMF Installment Agreement Default Notice
CP 523 notifies you that the IRS intends to terminate your installment agreement in 30 days.
You have the right to request an appeal if you do not agree by following the instructions in the notice.
CP 2000
You receive this letter when the IRS receives income, deduction or credit information that does not match your return. You are provided a computation of the proposed adjustments to your tax return based upon this information. If you agree, you sign and return the agreement forms.
If you do not agree, you can submit a request for appeal/protest to the office/individual that sent you the letter. The letter explains how to file a protest.
You need to file your protest within 30 days from the date of this letter in order to appeal the proposed adjustments with the Office of Appeals.
It is of utmost importance that you file a timely appeal.
Any appeal filed one day late will not be counted. Always make sure you send your appeal by certified mail and make sure you keep the receipt. If IRS can get out of working a case they will certainly do so.
Call us today for a free initial tax consultation and see if we can help you through the IRS appeals process.
by Fresh Start Tax | Jul 1, 2013 | Tax Help
If you need to file back tax returns who better to file back taxes than former IRS agents, managers and tax instructors.
Filing Taxes affordable is our expertise.
We have been practicing right here in South Florida since 1982 and we are A+ rated by the Better Business Bureau.
We have resolved thousands of cases since.
We have over 206 years of professional tax experience and over 60 years of working directly for the Internal Revenue Service in the local, district, and regional tax offices of the Internal Revenue Service.
We can guarantee that you will pay the lowest amount of tax allowed by law.
If you will owe money to the IRS
If you wind up owing money to the Internal Revenue Service we can work out a tax settlement for you.
Due to our years of experience at the Internal Revenue Service we can review every different tax option available and provide different solutions to you to completely and permanently remedy your problem
Did you know that if you do not file your tax return IRS can prepare a tax return for you?
It is critical you file your own tax return. You want to make sure you get full use of your Social Security and Medicare tax benefits and more importantly if you do not prepare your tax return IRS can prepare your tax return for you and they will do you no favor. Under 6020 of the Internal Revenue Code read the following:
(a) Preparation of return by Secretary
If any person shall fail to make a return required by this title or by regulations prescribed thereunder, but shall consent to disclose all information necessary for the preparation thereof, then, and in that case, the Secretary may prepare such return, which, being signed by such person, may be received by the Secretary as the return of such person.
(b) Execution of return by Secretary
(1) Authority of Secretary to execute return
If any person fails to make any return required by any internal revenue law or regulation made thereunder at the time prescribed therefor, or makes, willfully or otherwise, a false or fraudulent return, the Secretary shall make such return from his own knowledge and from such information as he can obtain through testimony or otherwise.
(2) Status of returns
Any return so made and subscribed by the Secretary shall be prima facie good and sufficient for all legal purposes.
Once the Internal Revenue Service prepares your tax return they will follow up with enforcement action.
They will follow up with the filing of a IRS bank levy, a IRS wage garnishment levy or the filing of a federal tax lien.
Call us today for free initial tax consultation and we can make filing back taxes an easy and simple process for you.
Areas of Professional Tax Representation
- On staff, Board Certified Tax Attorney’s, IRS Tax Lawyers, Certified Public Accountants, Enrolled Agents,
- Full Service Accounting Tax Firm,
- We taught Tax Law in the IRS Regional Training Center
- Former IRS Agents, Managers and Instructors with over 60 years experience in the local, district and regional IRS offices.
- Highest Rating by the Better Business Bureau “A” Plus
- Fast, affordable, and economical
- Licensed and certified to practice in all 50 States
- Nationally Recognized Veteran /Published Former IRS Agent
- Nationally Recognized Published EZINE Tax Expert
- As heard on GRACE Net Radio.com – Monthly Radio Show-Business Weekly
Areas of Professional Tax Practice:
- Same Day IRS Tax Representation
- Offers in Compromise or IRS Tax Debt Settlements
- Immediate Release of IRS Bank Levies or IRS Wage Garnishments
- Tax Relief from a IRS Bill, Letter or Notice of “Intent to Levy”
- IRS Tax Audits
- IRS Hardships Cases or Unable to Pay
- Payment Plans, Installment Agreements, Structured agreements
- Abatement of Penalties and Interest
- State Sales Tax Cases
- Payroll / Trust Fund Penalty Cases / 6672
- Filing Late, Back, Unfiled Tax Returns
- Tax Return Reconstruction
Filing Taxes – Back Tax – IRS Help with Affordable Former IRS Agents – Ft.Lauderdale, Miami – South Florida
by Fresh Start Tax | Jul 1, 2013 | Tax Help
Do not be bullied by the IRS.
If you want to fight with the IRS you have no better tool than to fight with former IRS agents and managers who know the IRS systems, protocols and settlement formulas.
If you are going through the IRS Tax audit process and are in need of professional tax help call affordable tax attorneys, certified public accountants and former IRS agents and managers who have over 206 of professional tax experience and over 60 years of working directly for the Internal Revenue Service.
We are true IRS tax experts when it comes to handling any and all IRS matters.
We are one of the leading tax advocates firms for IRS tax defense, both IRS audit and IRS collection matters.
So whether you are going through an IRS tax audit or need to file an IRS tax appeal contact us today for a free initial tax consultation.
You will speak directly to a tax attorney, certified public accountant, or former IRS agent, manager, tax instructor or the IRS appellate agent.
The IRS Appeal Process is the avenue to use to fight back if the IRS tax audit does not go your way.
IRS has an Administrative Appeals Process
The IRS has an administrative appeals process that works with taxpayers to try to settle tax disputes in an effort to avoid formal court hearings.
The role of IRS Audit Appeals is to make an independent review of a tax dispute and to consider the positions taken by both the taxpayer and the Service.
The Office of IRS Appeals unit strives to resolve tax disputes in a fair way and remain impartial to both parties.
The IRS will send you a report and/or letter that will explain the proposed adjustments or proposed or taken collection action.
The letter also tells you of your right to request a conference with an Appeals or Settlement Officer, as well as how to make your request for a conference.
In addition to examination adjustments, many other things can be appealed such as penalties, interest, trust fund recovery penalties, offers in compromise, liens, and levies. If you request an Appeals conference, be prepared with records and documentation to support your position.
Appeals conferences are informal meetings.
You may represent yourself or have an attorney, accountant, or an individual enrolled to practice before the IRS, represent you.
If you do not reach agreement with the Appeals or Settlement Officer, or you do not wish to appeal within the IRS, you may appeal certain actions through the courts.
Preparing A Request For IRS Appeals
Small Case Request
You prepare a small case request instead of a written protest if the total amount for any one tax period is $25,000 or less.
- Send a letter requesting Appeals consideration.
- Indicate the changes you do not agree with and the reason you don’t agree.
- For specific guidance in preparing a small case request/protest, refer to Form 12203, Request for Appeals Review.
Formal Written Protest
- Prepare a formal written protest for all of the following situations:
- If the total amount for any one tax period is greater than $25,000.
- Employee plan and exempt organization cases without regard to the dollar amount at issue.
- Partnership and S corporation cases without regard to the dollar amount at issue.
To prepare a formal written request for Appeals you must:
1. Include your name, address, social security number, and daytime telephone number.
2. Include a statement that you want to appeal the IRS findings to the Appeals office.
3. Include a copy of the letter showing the proposed changes and findings you don’t agree with (or the date and symbols from the letter).
4. Indicate the tax periods or years involved.
5. List all the changes you do not agree with and why you don’t agree.
6. State the facts supporting your position on any issue that you do not agree with.
7. Cite the law or authority, if any, on which you are relying.
8. Sign the written protest under the penalties of perjury.
You can represent yourself in Appeals, and you may bring another person with you to support your position.
The two most Frequently Asked Questions
Question -1 I sent in my appeal request/protest. How long will it be before I hear from the Appeals office?
Answer –1 This varies, depending on the type of case you are appealing and the time needed to review the file before sending your case to Appeals.
Normally, you can expect to hear from an Appeals employee within 90 days after you file your appeal request.
If more than 90 days have gone by and you still haven’t heard from Appeals, you should contact the office where you sent your appeal request.
They can tell you when they forwarded your case to Appeals.
If they were delayed in sending your case, you would not expect to hear from Appeals until at least 90 days from that date.
If more than 90 days have gone by and there is no known delay, ask that office to contact Appeals to get a time frame for when Appeals will contact you.
After researching the Appeals data base, they can tell you if your case has been assigned to an Appeals employee, their name and number and you can contact that employee directly.
Question 2 – How long will it take to resolve my case once it is received in Appeals?
Answer 2 – It depends on the facts and circumstances. It could take anywhere from 90 days to a year. Appeals continues to work towards reducing the time to resolve cases.
Your Appeals Officer or Settlement Officer can provide you with a more specific time frame.
Being a former IRS agent and teaching instructor you want to make sure you have a winnable case in appeals. Therefore I urge you to have your case thoroughly reviewed by a tax professional to make sure that you have a winnable case in the IRS appeals process. A good tax professional can help uses a process and save you a boatload of money.
Appeal IRS Tax Audit with Affordable Tax Attorneys & Former IRS
