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The TFA and the appeals process

Taxpayers in Georgia should be aware that the Taxpayer First Act changes the way the Internal Revenue Service conducts certain operations and procedures. This includes changes to how appeals are handled.

In accordance with the TFA, the Chief of Appeals oversees the Internal Revenue Service Independent Office of Appeals. Typically, all taxpayers have the right to appeal a decision by the IRS. The situations that are addressed by the TFA are those in which a taxpayer's appeal has been denied.

The IRS is required to give taxpayers a written notice that details the facts of their case and the justification for rejecting their right to obtain an appeal. The notice is also required to provide a thorough explanation of how the reason for denying the appeal pertains to the facts of the case. Taxpayers have the right to object to the denial of the appeal request. Also, the IRS is required to inform Congress, via an annual written report, of how many requests were denied and the reasons for denying them.

The TFA mandates that taxpayers are able to examine the unrestricted parts of the administrative file that pertains to the disputed issues no later than 10 days prior to the IRS Appeals conference. This differs from how taxpayers were allowed to access the nonprivileged parts of the file in the past as they were then required to submit a Freedom of Information Act or petition the Exam Team to ask for administrative files. These procedures for accessing taxpayer information were deemed time-consuming and onerous.

An attorney who practices tax law may assist clients with resolving disputes with the IRS. Counsel may be provided regarding the processes for appealing tax bills, stopping a wage levy or addressing an audit. If necessary, the attorney may advocate on behalf of clients at tax hearings.

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