IRS Tax Audits – Bad Results – Call Former Appeals Agents – local South Florida Experts

If you are or you have experienced a bad IRS Tax Audit, call us today.
You can speak to true affordable LOCAL tax experts.
You can speak directly to tax attorneys, certified public accountants, or former IRS appellate agents. We have over 206 years of professional tax experience.
We have been practicing right here in South Florida since 1982 and we are A+ rated by the Better Business Bureau.
Many taxpayers get stuck with the results of a bad tax audit for various reasons.
Sometimes you fail to answer IRS correspondence, many times you don’t have the proper records, your documentation  is insufficient, or sometimes even you can get stuck with the poor tax representative.
If you are not happy with the results of an IRS tax audit you have the ability to take your case to the IRS Tax Audit appeals office.
There are many people you can choose to hire to defend yourself in an IRS appellate tax audit.
Being former IRS agents, managers and IRS Appeals Agents, we know all the systems, all the protocols and all the hazards of litigation  procedures there are involved to settle your case.
You can contact us for a free initial consultation. Please find below the IRS appeals process for an IRS tax audit.
 

What are hazards of Litigation

 
A hazard of litigation is a term  frequently used  by the Internal Revenue Service. Each time a taxpayer files in appeal as a result of an IRS tax audit the Appellate Division must determine what are the hazards of litigation in case the file ends up in Tax Court. IRS evaluates the strength in their weakness of their case by the hazards of litigation.
Purpose and Organization of Appeals Settlement Guidelines
Appeals Settlement Guidelines (ASGs) are guidelines written by Appeals and reviewed by the Office of Chief Counsel to assist Appeals in coordinating issues of broad impact or importance to ensure resolution on a consistent basis nationwide.
In general, Appeals develops settlement guidelines when an issue is coordinated by the Examination function. Deputy Area Counsels (Industry Program) work with the Examination function to develop Coordinated Issue Papers (CIP), and the Office of Chief Counsel reviews these papers.
Settlement guidelines build on the core of a CIP by adding guidelines governing the settlement of issues, including addressing the hazards of litigation.
An ASG is generally organized into two sections: a law and analysis section and settlement guidelines section.
The ASG in its entirety must be reviewed by the Office of Chief Counsel for legal accuracy. Since ASGs are available to the public, subject to certain exemptions under the Freedom of Information Act (FOIA), the settlement guidelines section must also be reviewed by the Office of the Associate Chief Counsel (Procedure & Administration) to ensure that only privileged material is subject to redaction.
 

How do you File an Appeal with the IRS

 
The IRS Appeals Process
For those taxpayers who wish do this on there own, not recommended.
Before you prepare a request for a IRS Tax Audit Appeals, you will need to prepare a request for Appeals and mail it to the office that sent you the decision letter.
How to prepare for a “Request For Appeals”
 

Small Case Request for IRS Tax Audit Appeals

 
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.
1.  Send a letter requesting Appeals consideration.
2. 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 for a IRS Tax Audit Appeals

 
1. Prepare a formal written protest for all of the following situations:
2. If the total amount for any one tax period is greater than $25,000.
3. Employee plan and exempt organization cases without regard to the dollar amount at issue.
4. Partnership and S corporation cases without regard to the dollar amount at issue.
 

To prepare a formal written request for Appeals you MUST:

 
a. Include your name, address, social security number, and daytime telephone number.
b. Include a statement that you want to appeal the IRS findings to the Appeals office.
c. 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).
d. Indicate the tax periods or years involved.
e. List all the changes you do not agree with and why you don’t agree.
f. State the facts supporting your position on any issue that you do not agree with.
g. Cite the law or authority, if any, on which you are relying.
h. 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.
If you want to be represented by someone, the person you choose to represent you must be an attorney, a certified public accountant, or an enrolled agent authorized to practice before the IRS.
If you plan to have your representative talk to us without you, we need a copy of a completed power of attorney Form 2848, Power of Attorney and Declaration of Representative.
On staff at Fresh Start Tax LLC
Francis A. Andreacchi, Former IRS Revenue Agent, Appeal Agent
Former IRS Revenue Agent, Appeals Officer, Federal Tax Mediator, Gallatin Award form the U.S. Department of the Treasury.
With 35 years of employment with the Internal Revenue Service, Mr. Andreacchi has a vast amount of knowledge and experience. In 1974, he started as an Office Auditor in the Office Audit Division where he examined individual tax returns.
In 1982, Francis was promoted to Appeals Officer in the Appeals Division where he spent the last 35 years of his career with the IRS. As an Appeals Officer, he conducted conferences to settle cases in which taxpayers have appealed Internal Revenue Service determinations on their tax case or filed a petition in U.S. Tax Court.
Francis had the authority to recommend the final disposition of the case from the government’s perspective and to prepare the final settlement.
As an Appeals Officer, he was assigned various income tax cases involving individuals, trusts, partnerships and corporations from the Examination Division.
Frank is our TAX Audit Appeals Specialists.

IRS Tax Audits – Bad Results – Call Former Appeals Agents – Miami, Ft.Lauderdale, Boca, Palm Beaches