|
Do YOU or your client have a tax problem and need help now? Call (877) 829-8370 for a
|
Assuming your client’s offer in compromise was rejected by the IRS Offer Specialist assigned to their case, you have a few options as follows moving up the chain in seniority. You can appeal to the Specialist’s direct supervisor, the Group Manager. If you are unsuccessful you can request to argue your position to the Group [...]
These terms both refer to types of appeal. CAP stands for Collection Appeals Process and CDP stands for Collection Due Process.
Yes. See: If you submitted an appeal of an Offer In Compromise and it gets rejected where do you go?
Assuming your client’s offer in compromise was rejected by the IRS Offer Specialist assigned to their case, you have a few options as follows moving up the chain in seniority. You can appeal to the Specialist’s direct supervisor, the Group Manager. If you are unsuccessful you can request to argue your position to the Group [...]
Yes. The statute tolls (freezes) for the time the offer is under consideration plus 180 days plus 30 days for the rejection appeal period (IRM 5.1.19.3 (01-01-2006))
Effectively it is an audit re-consideration. You typically option the OIC doubt as to liability if all other appeal paths have been exhausted. For example if the 30 day and 90 day letters have been issued and the assessments are considered “final”. If this is not the case, a traditional audit reconsideration is the path [...]
If an audit becomes final including having exhausted all “official” channels of appeal; and the taxpayer failed to provide documentation supporting to either lower an assessment of tax liability or eliminate an assessment of tax liability (i.e. by providing proof of deductions or substantiating non-income deposits), the taxpayer may still have options. In many cases, [...]
It is impossible to guess at what motivates the IRS. They can appeal any ruling so it remains to be seen.
