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Appeals.

State Appeals functions vary for both collection activities as well as settlement activities. So they are not discussed here. For State Appeal processes, call Korntved & Associates.

Appeals is the third step in the settlement loop for the Internal Revenue Service. The Internal Revenue Service has Appeals availability for both collections issues as well as settlement rejections.

Appeals will usually provide relief with collection issues if taxpayers can show they are actually trying to resolve their tax problems. Relief may be in the form of levies being lifted or liens being removed or subordinated.

The one good thing with Appeals is that it has not been totally affected by all the unfriendly taxpayer changes that have occurred at the Internal Revenue Service over the last six or seven years. Fortunately, the personnel that work in Appeals are usually more skilled and do not necessarily have to adhere firmly to the Internal Revenue Manual.

Appeals is always available for offer in compromise rejections UNLESS the offer was an administrative rejection. Administrative rejections are commonly called ‘not processible’ offers and are a glorified collection tool.

Territories for Appeals are different in that some are not useful when it comes to offer rejections. Appeals in the California area is not helpful and is a glorified collection agency. The Florida area is better but not much better. Both of these areas are singled out because they handle overflows when the central offer offices are busy.

Let us take the California, Florida thing one step further. If an offer overflows to one of these locations, it is almost always a guaranteed pay-out-of-the nose-counter or rejection. So Appeals is almost always guaranteed when the offer goes there – and the Appeal must be guaranteed at the local geographical office of the taxpayer.

ANY TAXPAYER THAT HAS A REJECTED OFFER SHOULD ALWAYS REQUEST THAT THEIR APPEAL BE EVALUATED AT THEIR LOCAL GEOGRAPHICAL APPEALS OFFICE UNLESS THE OFFER IS EVALUATED AT ONE OF THE TWO CENTRAL OFFER EVALUATION OFFICES LOCATED IN HOLTSVILLE, NEW YORK OR MEMPHIS, TENNESSEE.

HOLTSVILLE AND MEMPHIS TEND TO ACCEPT MORE OF THE OFFERS AND THEIR APPEALS OFFICES TEND TO ACCEPT MORE OF THE REJECTED OFFERS. FOR ANYTHING ELSE, ASK FOR RELOCATION TO YOU APPEALS REGION.

The bottom line is that Appeals is step three in the settlement loop and taxpayers should be prepared to go there, because it happens frequently.