Abogados de Tax Appeals

Tax Appeals Lawyers in the United States

When you disagree with a tax assessment from the IRS or a state taxing authority, you have the right to challenge it. A tax appeals lawyer fights to reduce or eliminate tax liabilities that you believe are incorrect, excessive, or based on errors in your return or the agency's calculations.

What Tax Appeals Law Covers

Tax appeals law deals with disputes between taxpayers and government tax agencies. This covers challenges to income tax assessments, property tax valuations, payroll tax penalties, sales tax audits, and estate or gift tax determinations.

Lawyers in this field handle cases before the IRS Office of Appeals, the U.S. Tax Court, state tax tribunals, and local assessment boards. They also address penalty abatement requests, innocent spouse claims, and disputes over tax liens or levies. The IRS Independent Office of Appeals resolves roughly 100,000 cases per year without going to court.

When to Hire a Tax Appeals Lawyer

• You received an IRS notice of deficiency (also called a "90-day letter") proposing additional taxes owed
• Your property has been assessed at a value significantly higher than comparable properties in your area
• The IRS or a state agency has denied your penalty abatement request or rejected your offer in compromise
• You are facing a large tax bill from an audit and believe the examiner made errors in applying the tax code
• A tax lien or levy is threatening your wages, bank accounts, or real property

How the Tax Appeals Process Works

The process typically starts with an administrative appeal. After receiving an unfavorable determination, you file a written protest outlining the facts and legal arguments supporting your position. An appeals officer — someone separate from the original examiner — reviews the case.

If the administrative appeal fails, you can petition the U.S. Tax Court before paying the disputed amount, or pay the tax first and sue for a refund in federal district court. Most tax disputes settle before trial. The IRS reports that about 80% of cases brought to its appeals division reach some form of resolution without litigation.

How Tax Appeal Outcomes Are Determined

• Reassessed tax liability — the appeals officer or court may reduce the amount owed based on corrected income figures, allowable deductions, or proper application of tax credits
• Penalty reduction or removal — penalties for late filing, underpayment, or accuracy-related issues can be abated if you show reasonable cause
• Property tax reductions are calculated by comparing your assessed value against recent sales data and comparable properties
• Interest adjustments follow any reduction in the underlying tax — lower principal means lower accumulated interest
• Offers in compromise settle tax debts for less than the full amount based on your ability to pay, income, expenses, and asset equity

Frequently Asked Questions

How long does a tax appeal take?

Administrative appeals through the IRS typically take 6 to 12 months. Tax Court cases average 12 to 24 months from petition to resolution. Property tax appeals at the local level often move faster, sometimes concluding within a few months.

Can I appeal a tax decision without a lawyer?

You can represent yourself before the IRS appeals office or Tax Court. However, tax law is technical, and errors in your legal arguments or documentation can result in an unfavorable outcome. A lawyer experienced in tax controversy work understands how appeals officers evaluate cases and what evidence carries the most weight.