Pennsylvania IRS Administrative Appeals Law Firm, Dedicated to Protecting Your Rights
Within the IRS system, the Office of Appeals is intended to have final authority to determine tax liability and to function independently of the units whose determinations being appealed and to act "with strict impartiality between the taxpayer and the Government." The Office of Appeals' "mission statement" is "to resolve tax controversies without litigation on a basis which is fair and impartial to both the Government and the taxpayer in a manner that will enhance voluntary compliance and public confidence in the integrity and efficiency of the IRS." IRS Appeals Officers tend to be more experienced and better educated (some are attorneys and CPA's) and are permitted to weight the potential cost to the IRS of court litigation as a factor in evaluating an appeal. According to IRS statistics, about 85 to 90 percent of appeals filed by taxpayers are settled at the Appeals Office level.
In addition to Deficiency Appeals, which involve audits and examinations of tax returns, the Appeals Office also handles Collection Appeals, Refund Appeals and Assessable Tax and Penalty Appeals. Because of Appeals Officers' expertise in dispute resolution, the Appeals Office may be called upon to consider both cases in which no initial decision has been made as well as cases in which the taxpayer has chosen to bypass the Appeals process and sue the IRS in court.
Whether it is most advantageous to take advantage of the administrative appeals process or to proceed to court immediately in a given case can be a complicated strategic decision best made in consultation with experienced tax litigation counsel. Similar choices are available at various stages of IRS disputes of which the taxpayer is unlikely to be aware and which the IRS is under no obligation to point out.
Fast Track Mediation, now available with an Appeals Officer, is a streamlined process designed to expedite disputes involving audits, collections and settlement proposals rejected at the examinations level. The Appeals Officer will act as a mediator in the dispute between the IRS and the taxpayer at an early stage before a decision has been made. When a speedy decision is strategically desirable, Fast Track may be the way to go, depending on a number of factors.
Experienced, Efficient, Effective: Philadelphia Tax Appeal Attorney Joseph R. Viola
Joseph R. Viola is an experienced taxation attorney with almost 30 years of litigation experience on behalf of clients in greater Philadelphia and South Jersey. He is a skilled tax dispute and IRS administrative appeals lawyer you can trust.
Contact our full-service law office to schedule a free consultation. You can reach attorney Viola by toll-free phone call from Philadelphia County, Montgomery County, Bucks County, Delaware County, Chester County and Lehigh County of Pennsylvania and Camden County in New Jersey. Call 866-974-8841.
Joseph R. Viola, P.C. counsels tax appeal clients in cities such as Norristown, Media, Conshohocken, West Chester, Doylestown, King of Prussia, Drexel Hill, Ardmore, Bala Cynwyd, Bryn Mawr, Berwyn, Devon, Malvern, Merion, Paoli, Radnor, Rosemont, Villanova and Wayne.
For the Highest Level of Professional Representation and Personal Service, Contact Us
Your free initial consultation can be reserved at this toll-free phone number: 866-974-8841.
