The tax attorneys at Dilendorf Law Firm focus on helping clients appropriately reduce tax debts, and often recommend some form of tax appeal or settlement. Our firm represents taxpayers in a broad variety of federal and state tax planning and controversy matters for individuals and organizations.

TAX APPEAL AND TAX SETTLEMENTS

Telephone No.212.457.9797
The Tax Appeal Process
In New York, as in many other states of jurisdiction, local, state, and federal authorities have stepped up their tax collection efforts. This has resulted in more enforcement actions and audits for many taxpayers. Any encounter with a taxing authority over a tax debt could result in a devastating outcome for an individual’s personal investments, business, or other financial holdings.
An individual has the right to appeal the decision if they feel that an outcome from the IRS, state or local taxing authority is inaccurate or unfair, but this process is far more successful when handled by a tax appeals lawyer. When done correctly, the appeals process can help to substantially reduce an individual’s tax debt or eliminate it entirely. The tax specialists at Dilendorf Law Firm have the knowledge, expertise, and dedication to help our clients reach the desired resolution.
We help our clients navigate a complex appeals process
If an IRS audit yields an unacceptable result, the next step may be filing a protest with the Appeals division of the IRS. The Tax Appeals division’s mission is to resolve tax controversies fairly and impartially, without favoring the taxpayer or the government. The desired goal is to enhance voluntary compliance and public confidence while reducing the need for litigation.
An attorney in our practice will write an excellent written protest that lays out the facts in chronological order. We will clearly construct a legal argument for each issue, making the job of the Appeals officer much easier, which usually results in a more favorable outcome for our clients.
Once the Appeals office receives a protest, a conference is scheduled where the matter is reviewed to explore the prospects for a settlement. As both the fact finder and arbitrator, the Appeals officer’s goal is to gain agreement from both parties. The officer will take into consideration the “hazards of litigation” or the probability of the case not being upheld by a court. A favorable settlement is often reached when the IRS considers the likelihood of the case being dismissed by the court.
Is a Tax Appeal always the best option?
When an Appeals officer is unable to resolve an individual’s case, it will be referred to the federal courts. In some cases, an attorney might recommend skipping the appeals process and proceeding directly to court, but a protest with the Appeals division is usually a more viable path to resolution. Keep in mind, however, that an Appeals officer could research the matter further and find that original auditor missed certain details, revealing more tax liabilities.
Tax appeals can be a tricky and complex matter, with procedural consequences that lead to costly mistakes for the uninitiated. We recommend clients who have concerns about a potential tax appeal, or want to explore tax settlement options, should consult with the lawyers at Dilendorf Law Firm. Our attorneys have a successful track record of handling complicated appeals. From the protest stage to the federal courts, we stand by our clients every step of the way.
Resources:
- Appeals – Internal Revenue Service
- Considering an Appeal – Internal Revenue Service
- The Right to Appeal an IRS Decision in an Independent Forum
- Overview of Appeals Process – Internal Revenue Service
- NYC Tax Appeals Tribunal
- Estimating the Likelihood of Future Tax Settlements Using Firm Fundamental and Text Disclosures
- Learn about Offers in Final Settlement
- Settlement Reference Manual – Department of Justice, Tax Division

Telephone No.212.457.9797
For more information about our Tax Appeal services,
please contact Dilendorf Law Firm by sending an email or calling us at 212.457.9797