Guide index
Guides to IRS Appeals, CDP and Tax Court
Organized the way a dispute actually moves: administrative appeal, collection hearing, and litigation. Each guide cites the Internal Revenue Code, Treasury Regulations, Internal Revenue Manual, Tax Court Rules, and IRS publications it relies on.
IRS Appeals
Protests, settlement on hazards of litigation, and the programs that move a dispute out of the examiner's hands.
IRS Appeals Attorney in Tampa
IRS Appeals has broad settlement authority. An attorney gets better results.
How to Write a Formal Written Protest to IRS Appeals
The protest is the first document a neutral reviewer reads about your case. Write it like someone is going to grade it, because someone is.
The Small Case Request: A Shortcut Into IRS Appeals
If the amount is modest, you may not need a formal protest at all. But "you may not need" and "you should not write one" are two different things.
The Ex Parte Rules: Keeping IRS Appeals Independent
Appeals is supposed to be a fresh set of eyes. The ex parte rules are what keep the examiner from whispering in its ear.
Hazards of Litigation: How IRS Appeals Prices a Settlement
An examiner asks whether you are right. Appeals asks a better question: what would a judge do with this file?
Fast Track Settlement and Fast Track Mediation: When Speed Helps
Two IRS programs put an Appeals mediator in the room before the case ever leaves the examiner or revenue officer. Used at the right moment, they save months.
The Collection Appeals Program: Fast Review of Liens, Levies and Payment Plans
CAP is fast, broad, and final. That makes it a powerful tool and a dangerous one if you use it when a CDP hearing was still available.
Collection Due Process
The 30-day right to stop a levy, put collection alternatives in front of Appeals, and get a judge to review the result.
CDP Hearing Attorney Tampa
A Collection Due Process hearing is your right to challenge IRS collection.
Form 12153: Requesting a Collection Due Process Hearing the Right Way
Form 12153 is two pages long. It is also the document that decides whether a levy stops and whether a judge ever looks at your case.
Missed the CDP Deadline? The Equivalent Hearing Explained
Miss the 30-day CDP window and you still get a hearing. You just lose the two features that made it powerful.
Disputing the Tax Itself in a CDP Hearing
Most CDP hearings are about how to pay. Some are about whether you owe it at all. The difference turns on one sentence of the statute.
Inside a CDP Hearing: What the Settlement Officer Actually Does
A CDP hearing is usually a phone call and a stack of documents. Whether it works depends on what you send before the call and what you say on it.
The Lien CDP Hearing: Using Letter 3172 and IRC 6320
A lien notice comes with its own hearing right. It works differently from a levy hearing, and the timing is easy to misread.
Levy First, Hearing Later: The Post-Levy CDP Exceptions
The normal rule is notice, then hearing, then levy. Four exceptions flip the order. You still get a hearing. You just get it after the money is gone.
How the Tax Court Reviews a CDP Determination
A CDP case in Tax Court is not a do-over. It is a review of what Appeals did, measured against the record Appeals had.
The 30-Day Deadline to Petition After a CDP Determination
A Notice of Determination gives you 30 days, not 90. The Supreme Court softened that deadline in 2022. It did not make it optional.
U.S. Tax Court
From the 90-day letter to the decision: petitions, pleadings, discovery, stipulations, trial, and appeal.
Federal Tax Litigation in Tampa
When the IRS won\'t negotiate, the courtroom is where the answer lives.
Filing a Tax Court Petition from Tampa
The U.S. Tax Court lets you challenge the IRS before paying. Filing requires meeting strict deadlines.
How to Read a Notice of Deficiency, Page by Page
The 90-day letter is the most important piece of mail the IRS sends. It is also the one people most often misread.
When a Notice of Deficiency Is Invalid, and Why It Matters
Tax Court cases can be dismissed for two very different reasons. Which reason the court picks can decide whether the IRS can collect at all.
Rescinding a Notice of Deficiency: Form 8626 and IRC 6212(d)
Sometimes the best move after a notice of deficiency is to make it disappear. That takes the IRS's agreement, and the 90-day clock does not stop while you ask.
The Tax Court Small Case (S Case) Procedure: Pros, Cons and Limits
The small case procedure is simpler, faster, and friendlier. It is also final. Choose it because it fits the case, not because the name sounds less intimidating.
How to File a U.S. Tax Court Petition: Forms, Fees and Filing
A Tax Court petition is the single most protective document in federal tax practice. It is also surprisingly easy to get wrong in small ways that cost you issues.
Requesting Tampa as Your U.S. Tax Court Place of Trial
The Tax Court is based in Washington, D.C., but its judges travel. For Tampa Bay taxpayers, that means your trial can be here, if you ask for it.
The IRS Answer and Your Reply in Tax Court
After you file the petition, the IRS answers it. Most answers are routine. Some contain new allegations that you must respond to or risk having them deemed admitted.
Settling a Docketed Tax Court Case Through IRS Appeals
Filing a petition rarely means going to trial. It usually means a second, more focused round of settlement, with a trial date setting the pace.
Branerton Letters and Informal Discovery in Tax Court
In most federal courts, discovery starts with formal requests. In Tax Court, it starts with a letter and a conversation. Skip that step and the Court may send you back to it.
Stipulations of Fact in Tax Court: How Rule 91 Shapes Your Trial
In Tax Court, much of the trial happens on paper before anyone takes the stand. The stipulation of facts is that paper.
The Standing Pretrial Order and Calendar Call in Tax Court
The notice setting your case for trial starts the final countdown. The standing pretrial order that comes with it tells you exactly what to do and when.
Inside a Tax Court Trial: Burden of Proof, Evidence and Testimony
A Tax Court trial is a bench trial before a judge who hears tax cases all year. Knowing who has to prove what is most of the battle.
After the Opinion: Rule 155 Computations and the Tax Court Decision
The opinion tells you who won each issue. The decision tells you how much. Between the two is Rule 155, and it is not a formality.
Appealing a Tax Court Decision to the Eleventh Circuit
Tax Court is not always the last word. For Florida taxpayers, the next stop is the Eleventh Circuit, and the clock to get there is 90 days.
Qualified Offers and Recovering Litigation Costs From the IRS
If the IRS takes an unjustified position, or rejects a reasonable offer and then does worse at trial, the law can make it pay part of your costs.
The Section 6673 Penalty: When Tax Court Arguments Cost Up to $25,000
The Tax Court will hear almost any genuine dispute. It has no patience for arguments that the income tax does not apply to you, and Congress gave it a penalty to prove it.
Other IRS Matters
Examinations, collection defense, and the other matters this office handles.
Attorney-Client Privilege in IRS Cases
What you tell your CPA can be subpoenaed. What you tell your attorney cannot.
Criminal Tax Defense in Tampa
IRS Criminal Investigation has a 90%+ conviction rate. Your next call is to an attorney.
Florida Bankruptcy Tax Attorney
Florida\'s exemptions make bankruptcy a powerful tax elimination tool.
Foreign Account Compliance Attorney
FBAR and FATCA carry the highest penalties in tax law.
Innocent Spouse Attorney Tampa
Joint returns create joint liability. IRC 6015 provides three forms of relief.
IRS Attorney vs. Tax Preparer: What You Need to Know
Your tax preparer filed the returns. Now the IRS is auditing them. Your preparer cannot protect you the way an attorney can.
IRS Collection Alternatives Explained
Five paths out of IRS debt. An attorney evaluates all of them.
IRS Examination Attorney Tampa
An IRS examination is the government\'s chance to increase your tax. An attorney controls the scope.
IRS Hardship Attorney Tampa
When you genuinely cannot pay, the IRS has formal procedures.
IRS Levy Defense Attorney Tampa
The IRS seized your wages or bank account. An attorney can stop and reverse it.
IRS Lien Litigation Tampa
When administrative remedies fail, litigation forces lien resolution.
IRS Penalty Litigation Tampa
When penalty abatement is denied, litigation is the next step.
IRS Statute Expiration Attorney
The 10-year collection statute is a legal defense.
IRS Whistleblower Defense Tampa
Someone reported you to the IRS for a bounty. You need an attorney.
Offer in Compromise Attorney Tampa
An OIC is a legal negotiation with the federal government.
Tampa Business Tax Attorney
Tampa businesses face employment tax, corporate tax, and excise tax exposure.
Trust Fund Penalty Defense Tampa
The TFRP makes you personally liable. Defending requires legal strategy.
Unfiled Return Attorney Tampa
Unfiled returns create civil and potential criminal exposure.