Being a former IRS agent and teaching instructor I cannot tell you the amount of times that IRS has filed federal tax liens, federal tax levies unwarranted seizures of assets belonging to taxpayers.

Many taxpayers do not realize that you can appeal almost all IRS decisions if they are done on a timely matter.

Taxpayers can appeal decisions for the filing of the federal tax liens, for the filing of bank levies and wage garnishment notices or any seizure activity the IRS can take.

Below you can find the procedures to go ahead and appeal any of the IRS collection actions.

They must be done on a timely basis or you lose your appellate rights

If you have any questions you can contact us today we have over 60 years of direct IRS work experience

Appeals / Protests

A formal written protest is required in all cases to request an Appeals conference, unless you qualify for the Small Case Request procedure discussed below or another special appeal procedure.

Note:

If you disagree with a lien, levy, seizure, or denial or termination of an installment agreement, see Publication 1660, Collection Appeal Rights, for information on filing your protest.

How to file a Formal Written Protest

Include all of the following:

• Your name, address, and a daytime telephone number.

• A statement that you want to appeal the IRS findings to the Office of Appeals.

• A copy of the letter you received that shows the proposed change(s).

• The tax period(s) or year(s) involved.

• A list of each proposed item with which you disagree.

• The reason(s) you disagree with each item.

• The facts that support your position on each item.

• The law or authority, if any, that supports your position on each item.

The penalties of perjury statement as follows: “Under the penalties of perjury, I declare that the facts stated in this protest and any accompanying documents are true, correct, and complete to the best of my knowledge and belief.”
Your signature under the penalties of perjury statement.

If your representative prepares and signs the protest for you, he or she must substitute a declaration for the penalties of perjury statement that includes:

That he or she submitted the protest and any accompanying documents, and
Whether he or she knows personally that the facts stated in the protest and any accompanying documents are true and correct.

You must send your formal written protest within the time limit specified in the letter that offers you the right to appeal the proposed changes. Generally, the time limit is 30 days from the date of the letter.

How to file a Small Case Request, Appeal, Protest

You may submit a Small Case Request if the entire amount of additional tax and penalty proposed for each tax period is $25,000 or less.

For an offer in compromise, the entire amount for each tax period includes total unpaid tax, penalty and interest due.

Note:

Employee plan, exempt organizations, S corporations and partnerships are not eligible for Small Case Requests.

Follow the instructions in the letter you received.
Use Form 12203, Request for Appeals Review, or the form referenced in the letter to file your appeal, or prepare a brief written statement.

List the disagreed item(s) and the reason(s) you disagree.

IRS File a Tax Lien, Tax Levy, Seizure – Appeal the IRS Collection Action, Former IRS – Miami, Ft.Lauderdale, Palm Beaches