IRS appeals advocacy. Challenge the finding.
A disputed IRS finding can reach beyond a single return, affecting investment transactions, business income or several tax periods. We provide senior-led IRS appeals representation for high-net-worth individuals and businesses, developing a clear case for administrative resolution.
Appeals representation at a glance
The evidence shapes the argument.
The first step is to review the IRS determination, identify the disputed issues and confirm which appeal rights apply. We examine the notice, affected tax periods and response deadlines to establish the path forward.
For investors and business owners, the disagreement may turn on how a transaction was characterized, a deduction was substantiated or income was reported. We connect the IRS findings with the underlying financial record to establish the basis for the appeal.
What we consider
The determination and appeal route
The notice defines the issues and the route available to challenge them. For matters spanning several tax periods, each proposed adjustment must be considered within its applicable appeal rights and deadlines.
The facts and supporting record
Transaction documents, ownership agreements and financial records can explain details a tax return alone cannot. We organize relevant evidence around each contested item, showing how the facts support the taxpayer's treatment.
The protest and response position
A persuasive protest explains the disagreement with precision. We set out the contested findings, relevant facts and authority, then confirm that the request meets the submission requirements for the applicable procedure.
Representation and resolution options
Senior practitioners carry the case into discussions with the IRS under the appropriate authorization. As proposed terms emerge, we assess what they resolve, what remains contested and the implications for the individual or business.
A structured defense sequence
Our engagement follows the defense sequence outlined in our Tax Controversy practice, with the work shaped by the issues and stage of the appeal.
Notice intake
Review the determination, identify appeal rights and deadlines, and establish the representation and confidentiality framework.
Evidence build
Review the record, document the basis for disagreement and prepare the applicable protest or request.
Negotiation
Present the position, address questions and evaluate available administrative resolution options.
Resolution
Review the decision or proposed agreement, document the outcome and assess any remaining steps.
Appeals representation in context
An appeal takes shape around the finding being challenged. The hypothetical situations below show how evidence and procedural rights can guide the response.
An investor disputing an examination adjustment
The IRS proposes treating an investor's transaction proceeds differently from the filed return. Transaction agreements, payment records and the stated basis for the adjustment help establish whether an administrative challenge is supported.
A business owner challenging disallowed deductions
An examination disallows expenses associated with a business owner's operations. Connecting those deductions with their business purpose and documentation helps identify which adjustments have a supported basis for appeal.
A corporation facing disputed tax treatment
A corporation faces income or deduction adjustments across several tax periods. Mapping the findings to each period and the underlying financial records helps develop a coherent case for administrative review.
Explore tax controversy and dispute resolution.A taxpayer appealing a penalty relief denial
A high-net-worth taxpayer receives a penalty relief denial within a substantial tax dispute. The reasons given, prior submissions and available appeal rights guide the next response and any further evidence needed.
Questions about IRS appeals representation
Common questions about appeals engagements — whether an appeal is available, what to bring, preparing for an Appeals conference, and timing and outcomes.
Give your position a clear direction.
Bring your IRS determination into a confidential strategy conversation with a senior practitioner. Together, we can identify the issues that merit challenge, the evidence needed and the administrative path available.