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Tuesday, January 1, 2008 

Are you in the middle of a disagreement with the IRS? One of the guaranteed rights for all taxpayers

Are you in the middle of a disagreement with the IRS? One of the guaranteed rights for all taxpayers is the right to a eal. If you disagree with the IRS about the amount of your tax liability or about proposed collection actio , you have the right to ask the IRS A eals Office to review your case.

During their contact with taxpayers, IRS employees are required to explain and protect these taxpayer rights, including the right to a eal. The IRS a eals system is for people who do not agree with the results of an examination of their tax retur or other adjustments to their tax liability. In addition to examinatio , you can a eal many other things, including:

1. Collection actio such as lie , levies, seizures, i tallment agreement terminatio and rejected offers-in-compromise,

2. Penalties and interest, and

3. Employment tax adjustments and the trust fund recovery penalty.

Internal IRS A eal conferences are informal meetings. The local A eals Office, which is independent of the IRS office, can sometimes resolve an a eal by telephone or through corre ondence.

The IRS also offers an option called Fast Track Mediation, during which an a eals or settlement officer attempts to help you and the IRS reach a mutually satisfactory solution. Most cases not docketed in court qualify for Fast Track Mediation. You may request Fast Track Mediation at the conclusion of an audit or collection determination, but prior to your request for a normal a eals hearing. Fast Track Mediation is meant to promote the early resolution of a di ute. It doe t eliminate or replace existing di ute resolution optio , including your o ortunity to request a conference with a manager or a hearing before A eals. You may withdraw from the mediation proce at any time.

When attending an informal meeting or pursuing mediation, you may represent yourself or you can be represented by an attorney, certified public accountant or individual enrolled to practice before the IRS.

If you and the IRS a eals officer ca ot reach agreement, or if you prefer not to a eal within the IRS, in most cases you may take your disagreement to federal court. Usually, it is worth having a go at mediation before committing to an expe ive and time-co uming court proce .

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