If it is not possible to resolve a case with the Internal Revenue Service Examination Division, we routinely counsel clients on the merits of an administrative appeal before the Internal Revenue Service Appeals Division. Assuming an administrative appeal is warranted, the firm has substantial experience in preparing written protest letters, thereby triggering the client’s administrative appeal rights.
Unlike the Examination Division, the Internal Revenue Service Office of Appeals is independent from the Examination Division. The stated mission of the Office of Appeals is to
resolve tax controversies without litigation on a fair and impartial basis to both the government and the taxpayer in a manner that enhances voluntary compliance and public confidence. Because of these twin objectives, approximately ninety percent (90%) of all taxpayers utilizing the administrative appeals process are able to settle their cases without litigation.
Sometimes the administrative appeals process lends itself to obtaining technical advice memorandum (TAM) or private letter rulings from the National Office of the Internal Revenue Service, Office of Chief Counsel. In these cases, our National Office practice may serve as a means for resolving thorny issues without resorting to litigation.