Civil & Criminal Appeals Concerning Income Taxes, Estate Taxes, and Gift Taxes
Boston tax lawyer Theodore L. Craft is experienced in representing clients in tax appeals. His 35 years of knowledge dealing with criminal tax cases and investigations lends credibility to a client’s case and comfort to the client.
Tax appeals are entertained on all income tax, estate tax, and gift tax matters, whether civil or criminal, in the offices of regional appeals of the Internal Revenue Service (IRS).
A tax appeal may be initiated by in a number of ways, including as a:
Protest from a finding in a tax audit
Protest in a forced tax collection matter
Collection appeal from an IRS action, such as a tax lien or levy
Collection due process appeal, which entitles the taxpayer to a hearing before his property is taken by levy or taxed by lien.
There are specific statutory provisions governing tax appeals and they are very technical in nature. An appeal generally is undertaken to introduce other and further evidence not introduced at the district level in a tax audit or collection. There is no appeal to the IRS regional appeals office in a criminal matter. A criminal matter must be concluded before an appeal can be initiated.
IRS Office of Regional Appeals
The IRS Office of Regional Appeals handles all appeals on evidence submitted, and views evidence on the basis of hazards of litigation. In other words, if the taxpayer's evidence presents a hazard to the IRS that it could lose an issue because of the strength of evidence presented by the taxpayer, or the case law upon which the taxpayer depends, it may resolve an issue in a taxpayer's favor or concede an issue to the taxpayer. The IRS district level does not have this discretion; therefore, an appeal is advisable in many cases.
Schedule a consultation: Contact Boston tax appeal lawyer Theodore L. Craft.