- IRS Administrative Procedure - Once you have disagreed with the Revenue Agent, you simply either Appeal adminstratively or ask for a Notice of Deficency. The Agent's determinations are not binding on either the IRS or the Taxpayer. The Agent's determinations are only a starting point.
- Administrative Appeals - To Appeal or Not? - It is a very important decision whether or not to appeal a Revenue Agent's determination. There are times when you may want to appeal, but it would be somewhat rare, as if you go to Tax Court first, you always have to meet with an IRS Appeals Officer.
- Tax Court - It is often less expensive for a client to go directly to Tax Court from a Revenue Agent's Decision. The fee is $60.00 and the Petition is very short and simple. The advantage is that all issues become fixed. The audit cannot be reopened unless the IRS assumes the burden of proof.
