by Fresh Start Tax | Jun 3, 2013 | Tax Help
Best IRS Tax Problem Help – Former IRS Agents, Managers
There are several excellent tax firms in the South Florida area.
Fresh Start Tax considers themselves one the very best IRS tax resolution firm’s in the area.
We have been in private practice right here in South Florida since 1982.
We are A+ rated by the Better Business Bureau and we are without complaint.
The Better Business Bureau is one of the very best confirmations of who is best for IRS tax problem help.
When you are considering hiring a local tax firm for an IRS tax matter, situation or tax problem, the Better Business Bureau provides the best type of grading system available.
If you are looking for IRS tax help it only makes sense to hire former IRS agents, managers and tax instructors.
We have over 60 years of working directly for the IRS and the local South Florida office as agents, instructors, managers, and former IRS appellate agents.
Hire Former Local IRS Agents who taught Tax Law at the IRS.
We have a combined 205 years of total IRS work experience.
We taught Tax Law out of the local district and regional IRS offices.
You may call us for a no cost professional tax consultation or visit our offices.
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 if Tax Records are lost or destroyed
IRS Help
Our Company Resume: ( Since 1982 )
Our staff has collectively over 205 years of Professional IRS Tax Representation Experience
On staff, Board Certified Tax Attorney’s, IRS Tax Lawyers, Certified Public Accountants, Enrolled Agents,
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”
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Best IRS Tax Problem Help – Ft.Lauderdale, Miami, Palm Beaches – Affordable Former IRS Agents – South Florida
by Fresh Start Tax | Jun 3, 2013 | IRS Tax Audit

Federal Tax Audits, IRS Supervisors- Former IRS
If you are going to undergo a federal tax audit contact us today for a free initial tax consultation and find out how we can make this a worry free federal tax audit.
We are comprised of tax attorneys, IRS tax lawyers, certified public accountants, and former IRS agents, managers and tax instructors who have logged over 60 years of direct federal tax audit experience at the Internal Revenue Service.
We have been in private practice since 1982 and we are A+ rated by the Better Business Bureau.
We are experts in IRS federal tax representation. We taught tax law at the Internal Revenue Service.
Being former IRS agents and managers we know all the protocols, all the systems and all the IRS settlement procedures.
If you are going to retain any tax professional you want to make sure you hire the most experienced, affordable and by all means former IRS agents who know exactly how to get your very best result.
Why does IRS conduct a Federal Tax Audit
The IRS examines (audits) tax returns to verify that the tax reported is correct. The Internal Revenue Service audits of millions of taxpayers every year. IRS conducts 1.4 million audits alone and W-2, 1099 mismatching.
Selecting a federal tax return for a tax examination does not always suggest that the taxpayer has either made an error or been dishonest.
In fact, some federal tax audit examinations result in a refund to the taxpayer or acceptance of the return without change.
The overwhelming majority of taxpayers files returns and make payments timely and accurately. Taxpayers have a right to expect fair and efficient tax administration from the IRS, including verification that taxes are correctly reported and paid with enforcement actions against those who fail to comply voluntarily.
Do not be bullied, you have Taxpayer Rights
The IRS trains its employees to explain and protect taxpayers’ rights throughout their contacts with taxpayers. however this is not always the case. You need to be aware of your taxpayer Bill of Rights. With IRS targeting certain people, industries and nonprofit organizations these Bill of Rights people can become critical during an IRS tax audit.
These rights include:
- A right to professional and courteous treatment by IRS employees.
- A right to privacy and confidentiality about tax matters.
- A right to know why the IRS is asking for information, how the IRS will use it and what will happen if the requested information is not provided.
- A right to representation, by oneself or an authorized representative.
- A right to appeal disagreements, both within the IRS and before the courts.
How Federal Tax Income Tax Returns Are Selected for Examination
The IRS selects tax returns using a variety of methods, including:
- Potential participants in abusive tax avoidance transactions — Some returns are selected based on information obtained by the IRS through efforts to identify promoters and participants of abusive tax avoidance transactions. Examples include information received from “John Doe” summonses issued to credit card companies and businesses and participant lists from promoters ordered by the courts to be turned over to the IRS.
- Computer Scoring — Some returns are selected for examination on the basis of computer scoring. Computer programs give each return numeric “scores”. The Discriminant Function System (DIF) score rates the potential for change, based on past IRS experience with similar returns. The Unreported Income DIF (UIDIF) score rates the return for the potential of unreported income. IRS personnel screen the highest-scoring returns, selecting some for audit and identifying the items on these returns that are most likely to need review. the computer scoring audit is the most common tax audit that will be conducted by the Internal Revenue Service. Fresh Start Tax has on staff a former IRS agent who actually was part of the computer scoring process.
- Large Corporations — The IRS examines many large corporate returns annually.For tax returns over $10m , you have a 28% chance of a IRS tax audit.
- Information Matching — Some returns are examined because payer reports, such as Forms W-2 from employers or Form 1099 interest statements from banks, do not match the income reported on the tax return. IRS conducted 1.4 million information matching audits last year alone.
- Related Examinations — Returns may be selected for audit when they involve issues or transactions with other taxpayers, such as business partners or investors, whose returns were selected for examination. These related examinations are usually a result of corporate or partnership tax audits that carryover to individuals individual tax returns.
- Other — Area offices may identify returns for examination in connection with local compliance projects. These projects require higher level management approval and deal with areas such as local compliance initiatives, return preparers or specific market segments. You can find a list of the specific market segment tax audits on our website.
Federal Tax Audit Examination Methods
An examination may be conducted by mail or through an in-person interview and review of the taxpayer’s records. The interview may be at an IRS office (office audit) or at the taxpayer’s home, place of business, or accountant’s office (field audit).
Taxpayers may make audio recordings of interviews, provided they give the IRS advance notice.
If the time, place, or method that the IRS schedules is not convenient, the taxpayer may request a change, including a change to another IRS office if the taxpayer has moved or business records are there. It is always best to have the federal tax audit conducted at the location of your tax professional. You should never have a IRS federal tax on it in your home, office, or place of business.
The audit notification letter tells which records will be needed. Taxpayers may act on their own behalf or have someone represent or accompany them. If the taxpayer is not present, the representative must have proper written authorization.
The auditor will explain the reason for any proposed changes. Most taxpayers agree to the changes and the audits end at that level.
Your Federal Tax Audit Appeal Rights
Appeal Rights are explained by the examiner at the beginning of each audit. Taxpayers who do not agree with the proposed changes may appeal by having a supervisory conference with the examiner’s manager or appeal their case administratively within the IRS, to the U.S. Tax Court, U.S. Claims Court or the local U.S. District Court.
If there is no agreement at the closing conference with the examiner or the examiner’s manager, the taxpayer has 30 days to consider the proposed adjustments and their next course of action. If the taxpayer does not respond within 30 days, the IRS issues a statutory notice of deficiency, which gives the taxpayer 90 days to file a petition to the Tax Court.
The Claims Court and District Court generally do not hear tax cases until after the tax is paid and administrative refund claims have been denied by the IRS. The tax does not have to be paid to appeal within the IRS or to the Tax Court.
A case may be further appealed to the U.S. Court of Appeals or to the Supreme Court, if those courts accept the case.
Remember the decision of the local IRS agent is not final.
You have appellate rights. Just for the record on staff of Fresh Start Tax , a former IRS appeals agent as well as tax attorneys to handle any appeals or Tax Court cases.
Federal Tax Audits, IRS Representation – Former IRS Management Representation – Affordable IRS Audit Experts
by Fresh Start Tax | Jun 3, 2013 | Tax Audit
IRS Help – Tax Audit Representation 954-492-0088
There is nobody better to help defend an IRS tax audit than a former local IRS agents, managers or tax instructors.
Since we were trained by the Internal Revenue Service we know all the IRS tax audit protocols, the IRS tax audit systems, and all the IRS tax audit settlement formulas.
We have represented thousands of taxpayers before the Internal Revenue Service right here in South Florida and you should let that experience work for you.
Not only were we former IRS agents, and managers we also taught tax law at the Internal Revenue Service. We are experts for IRS Tax Help for tax Audit Representation.
As some practical advice, before you make a decision to hire an IRS tax audit representative for IRS tax help, make sure you personally meet and talk directly to the tax professional who will be working your case. Find out for yourself about their work experience, their ethic and their fees.
Common questions asked by clients
Does filing an amended return affect the return selection process?
Filing an amended return does not affect the selection process of the original return. However, amended returns also go through a screening process and the amended return may be selected for audit. If you have found an error in your tax return it is important you correct your return and file an amended 1040 X.
Why was my tax return selected for tax audit?
When returns are filed, they are compared against “norms” for similar returns. The “norms” are developed from audits of a statistically valid random sample of returns.
These tax returns are selected as part of the National Research Program which the IRS conducts to update return selection information.
The tax return is next reviewed by an experienced auditor. At this point, the return may be accepted as filed, or if based on the auditor’s experience questionable items are noted, the agent will identify the items noted and the return is forwarded for assignment to an examining group.
Upon assignment to a group, the return is reviewed by the manager.
Items considered in assigning a case are: factors particular to the area such as issues pertaining to construction, farming, timber industry, etc. that have specific factors and rules that apply.
Based on the review, the manager can accept the return or assign the return to an auditor. The assigned auditor again reviews the return for questionable items and either accepts it as filed or contacts the taxpayer to schedule an appointment. Many times the manager will not schedule the tax at an all because of high inventories in the local offices.
Where will the IRS Tax audit be held?
It depends on the type of audit being conducted.
- 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.
- In-Person Audits are audits conducted either at a local IRS office or at your business location.
Can you request the IRS Tax 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.
It is always best to hire a tax professional and transfer your books and records to the office of the tax representative that you have hired.
As a former IRS agent I would never recommend any taxpayer ever have an audit conducted at their house, office, or place of business.
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. A decision is made on a case-by-case basis and there is no rule of thumb.
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 IRS 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 back tax return, The Statute of Limitations.
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 IRS tax 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.
IRS Help – Tax Audit Representation – Affordable Former IRS Agents – Ft.Lauderdale, Miami, Palm Beaches – Audit Experts
by Fresh Start Tax | Jun 3, 2013 | IRS Tax Audit, IRS Tax Experts

IRS Tax Audit Examination – Affordable Tax Audit Relief
Do not be bullied around by an IRS tax audit examination. Let former IRS agents and managers fight back because we know the systems and protocols.
Hire Former IRS Audit Managers and Supervisors for a IRS Tax Audit Examination.
We are local tax experts practicing right here in South Florida since 1982 and we are A+ rated by the Better Business Bureau.
Our firm has a combined 60 years of direct IRS work experience in the local South Florida IRS tax offices.
As former IRS Agents and Managers we worked in a local, district, and regional tax offices of the IRS.
If you are going to undergo a federal tax audit it only makes sense to hire former IRS agents, managers and tax instructors who know all the inner workings of the Internal Revenue Service.
We are comprised of tax attorneys, tax lawyers, certified public accountants, enrolled agents, and former IRS agents.
As former IRS auditors and managers we know all the protocols, all systems, and all the settlement formulas and techniques to marginalize any IRS tax audit.
While working at Internal Revenue Service we taught tax law and taught new IRS Agents the exact protocols for the IRS Tax Audit Examinations.
Why a IRS Tax Audit Examination
IRS audits federal tax returns to verify that the correct tax reported is correct.
Selecting a tax return for a IRS tax examination does not always suggest that the taxpayer has either made an error or been dishonest.
In fact, some IRS tax examinations result in a refund to the taxpayer or acceptance of the return without change. These are called no-changes.
The overwhelming majority of taxpayers files returns and make payments timely and accurately.
Taxpayers have a right to expect fair and efficient tax administration from the IRS, including verification that taxes are correctly reported and paid with enforcement actions against those who fail to comply voluntarily. There are procedures if you feel the tax auditor is targeting you or is unfairly dealing with your situation.
How do you when to hire a tax professional or do it yourself
Being a former IRS agent and instructor I can tell you that there are times that taxpayers may represent themselves during an IRS federal tax audit.
The rule of thumb is quite simple, if you have a clean tax return and have all documentation by all means represent yourself during an IRS tax audit examination.
If you have any issues, concerns, or problems that you think may arise it is absolutely in your best interest to hire a certified tax professional.
Your Taxpayer Rights during a IRS Tax Audit Examination
The IRS trains its employees to explain and protect taxpayers’ rights throughout their contacts with taxpayers. Sometimes this happens and sometimes it doesn’t.
These IRS Tax Audit Examination rights include:
1. A right to professional and courteous treatment by IRS employees.
2. A right to privacy and confidentiality about tax matters.
3. A right to know why the IRS is asking for information, how the IRS will use it and what will happen if the requested information is not provided.
4. A right to representation, by oneself or an authorized representative.
5. A right to appeal disagreements, both within the IRS and before the courts.
How IRS Tax Audit Examination Tax Returns Are Selected for Examination
The IRS selects tax returns using a variety of methods, including:
- Potential participants in abusive tax avoidance transactions. Some returns are selected based on information obtained by the IRS through efforts to identify promoters and participants of abusive tax avoidance transactions. Examples include information received from “John Doe” summonses issued to credit card companies and businesses and participant lists from promoters ordered by the courts to be turned over to the IRS.
- Computer Scoring. Some returns are selected for examination on the basis of computer scoring. Computer programs give each return numeric “scores”. The Discriminant Function System (DIF) score rates the potential for change, based on past IRS experience with similar returns. The Unreported Income DIF (UIDIF) score rates the return for the potential of unreported income. IRS personnel screen the highest-scoring returns, selecting some for audit and identifying the items on these returns that are most likely to need review.
- Large Corporations . The IRS examines many large corporate returns annually.
- Information Matching. Some returns are examined because payer reports, such as Forms W-2 from employers or Form 1099 interest statements from banks, do not match the income reported on the tax return. 1.4 million tax returns are audited via this information matching method.
- Related Examinations. Federal Tax Returns may be selected for audit when they involve issues or transactions with other taxpayers, such as business partners or investors, whose returns were selected for examination. Many times these IRS tax audit examinations carry through when corporate or partnership tax returns are audited and the IRS tax examiner feels it’s necessary to pick up the tax returns of individuals.
- Other. Area offices may identify returns for examination in connection with local compliance projects. These projects require higher level management approval and deal with areas such as local compliance initiatives, return preparers or specific market segments. Each district in each region has specialized tax audits. Many times these are referred to as the market specialization program audits. You can find a list of the market specialization program tax audits on our website.
It should also be known that IRS changes its tax examination audit strategies depending on administrations and current federal mandates. It is best to check with us directly to find out which programs and methods will be used during your IRS tax audit examination.
IRS Tax Audit Examination Methods
An IRS Federal examination may be conducted by mail or through an in-person interview and review of the taxpayer’s records.
The interview may be at an IRS office or at the taxpayer’s home, place of business, or accountant’s or tax professionals office.
Taxpayers may make audio recordings of interviews, provided they give the IRS advance notice.
If the time, place, or method that the IRS schedules is not convenient, the taxpayer may request a change, including a change to another IRS office if the taxpayer has moved or business records are there.
The audit notification letter tells which records will be needed. Taxpayers may act on their own behalf or have someone represent or accompany them. If the taxpayer is not present, the representative must have proper written authorization.
The auditor will explain the reason for any proposed changes. Most taxpayers agree to the changes and the audits end at that level.
IRS Tax Audit Examination Appeal Rights
IRS Federal Appeal Rights are explained by the examiner at the beginning of each audit. Taxpayers who do not agree with the proposed changes may appeal by having a supervisory conference with the examiner’s manager or appeal their case administratively within the IRS, to the U.S. Tax Court, U.S. Claims Court or the local U.S. District Court.
If there is no agreement at the closing conference with the examiner or the examiner’s manager, the taxpayer has 30 days to consider the proposed adjustments and their next course of action.
If the taxpayer does not respond within 30 days, the IRS issues a statutory notice of deficiency, which gives the taxpayer 90 days to file a petition to the Tax Court. The Claims Court and District Court generally do not hear tax cases until after the tax is paid and administrative refund claims have been denied by the IRS.
The tax does not have to be paid to appeal within the IRS or to the Tax Court. A case may be further appealed to the U.S. Court of Appeals or to the Supreme Court, if those courts accept the case.
IRS Tax Audit Examination – Affordable Tax Audit Relief – Miami, Ft.Lauderdale, Palm Beaches – CPA’s, Former IRS
by Fresh Start Tax | Jun 3, 2013 | IRS Tax Audit

Federal Tax Audits – Affordable Expert Representation 1-866-700-1040
We are local tax experts practicing right here in South Florida since 1982.Free initial tax consultations.
We have a combined 60 years of direct IRS work experience in the local South Florida tax offices. As former IRS employees we worked in a local, district, and regional tax offices of the IRS.
We worked as supervisors, managers, and taught tax law and the local, district, and regional tax offices. We are the real deal and we are affordable.
If you are going to undergo a federal tax audit it only makes sense to hire former IRS agents, managers and tax instructors who know all the inner workings of the Internal Revenue Service.
With over a combined 60 years of IRS experience we are one of the most experienced tax firms, we can represent taxpayers in all 50 states for IRS federal tax audits.
We are comprised of tax attorneys, tax lawyers, certified public accountants, enrolled agents, and former IRS agents.
As former IRS auditors and managers we know all the protocols, all systems, and all the settlement formulas and techniques to marginalize any IRS tax audit.
While working at Internal Revenue Service we taught tax law.
We are A+ rated by the Better Business Bureau and been in private practice since 1982.
We are experts when it comes to IRS federal tax audits. We are the affordable tax firm.
Why a IRS Federal Tax audit
IRS examines federal tax returns to verify that the tax reported is correct.
Selecting a return for examination does not always suggest that the taxpayer has either made an error or been dishonest.
In fact, some IRS tax examinations result in a refund to the taxpayer or acceptance of the return without change.
The overwhelming majority of taxpayers files returns and make payments timely and accurately. Taxpayers have a right to expect fair and efficient tax administration from the IRS, including verification that taxes are correctly reported and paid with enforcement actions against those who fail to comply voluntarily.
How do you when to hire a tax professional or do it yourself
Being a former IRS agent I can tell you that there are times that taxpayers may represent themselves during an IRS federal tax audit.
The rule of thumb is quite simple, if you have a clean tax return and have all documentation by all means represent yourself during an IRS Federal tax audit.
If you have any issues, concerns, or problems that you think may arise it is absolutely in your best interest to hire a certified local tax professional. You should always meet the person face to face who will be handling your IRS federal tax audit defense.
Your Taxpayer Rights
The IRS trains its employees to explain and protect taxpayers’ rights throughout their contacts with taxpayers.
These rights include:
1. A right to professional and courteous treatment by IRS employees.
2. A right to privacy and confidentiality about tax matters.
3. A right to know why the IRS is asking for information, how the IRS will use it and what will happen if the requested information is not provided.
4. A right to representation, by oneself or an authorized representative.
5. A right to appeal disagreements, both within the IRS and before the courts.
How Federal Tax Returns Are Selected for Examination
The IRS selects returns using a variety of methods, including:
- Potential participants in abusive tax avoidance transactions — Some returns are selected based on information obtained by the IRS through efforts to identify promoters and participants of abusive tax avoidance transactions. Examples include information received from “John Doe” summonses issued to credit card companies and businesses and participant lists from promoters ordered by the courts to be turned over to the IRS.
- Computer Scoring — Some returns are selected for examination on the basis of computer scoring. Computer programs give each return numeric “scores”. The Discriminant Function System (DIF) score rates the potential for change, based on past IRS experience with similar returns. The Unreported Income DIF (UIDIF) score rates the return for the potential of unreported income. IRS personnel screen the highest-scoring returns, selecting some for audit and identifying the items on these returns that are most likely to need review.
- Large Corporations — The IRS examines many large corporate returns annually.
- Information Matching — Some returns are examined because payer reports, such as Forms W-2 from employers or Form 1099 interest statements from banks, do not match the income reported on the tax return. 1.4 million tax returns are audited via this information matching method.
- Related Examinations — Federal Tax Returns may be selected for audit when they involve issues or transactions with other taxpayers, such as business partners or investors, whose returns were selected for examination.
- Other — Area offices may identify returns for examination in connection with local compliance projects. These projects require higher level management approval and deal with areas such as local compliance initiatives, return preparers or specific market segments. Each district in each region has specialized tax audits. Many times these are referred to as the market specialization program.
Federal IRS Examination Methods
An IRS Federal examination may be conducted by mail or through an in-person interview and review of the taxpayer’s records. The interview may be at an IRS office (office audit) or at the taxpayer’s home, place of business, or accountant’s office (field audit).
Taxpayers may make audio recordings of interviews, provided they give the IRS advance notice.
If the time, place, or method that the IRS schedules is not convenient, the taxpayer may request a change, including a change to another IRS office if the taxpayer has moved or business records are there.
The audit notification letter tells which records will be needed. Taxpayers may act on their own behalf or have someone represent or accompany them. If the taxpayer is not present, the representative must have proper written authorization.
The auditor will explain the reason for any proposed changes. Most taxpayers agree to the changes and the audits end at that level.
IRS Federal Appeal Rights
IRS Federal Appeal Rights are explained by the examiner at the beginning of each audit. Taxpayers who do not agree with the proposed changes may appeal by having a supervisory conference with the examiner’s manager or appeal their case administratively within the IRS, to the U.S. Tax Court, U.S. Claims Court or the local U.S. District Court.
If there is no agreement at the closing conference with the examiner or the examiner’s manager, the taxpayer has 30 days to consider the proposed adjustments and their next course of action.
If the taxpayer does not respond within 30 days, the IRS issues a statutory notice of deficiency, which gives the taxpayer 90 days to file a petition to the Tax Court. The Claims Court and District Court generally do not hear tax cases until after the tax is paid and administrative refund claims have been denied by the IRS.
The tax does not have to be paid to appeal within the IRS or to the Tax Court. A case may be further appealed to the U.S. Court of Appeals or to the Supreme Court, if those courts accept the case.
IRS Federal Tax Audits – Affordable Attorneys, Lawyers, CPA’s, Former IRS – Miami, Ft.Lauderdale, Palm Beaches – South Florida