alberghi soggiorno Porto countryPost Filing Issues
Understanding You Rights
Your Appeal Rights/How to Prepare a Protest if You Don't Agree

If you don't agree with any or all of the IRS findings given you,you may request a meeting or a telephone conference with the supervisor of the person whoissued the findings. If you still don't agree, you may appeal your case to the AppealsOffice of IRS.

hotel a InterlakenIf you decide to do nothing and your case involves anexamination of your income, estate, gift, and certain excise taxes or penalties, you willreceive a formal Notice of Deficiency. The Notice of Deficiency allows you to go to theTax Court and tells you the procedure to follow. If you do not go to the Tax Court, wewill send you a bill for the amount due.

If you decide to do nothing and your case involves a trustfund recovery penalty, or certain employment tax liabilities, the IRS will send you a billfor the penalty. If you do not appeal a denial of an offer in compromise or a denial of apenalty abatement, the IRS will continue collection action. If you don't agree, we urgeyou to appeal your case to the Appeals Office of IRS. The Office of Appeals can settlemost differences without expensive and time-consuming court trials. [Note: Appeals can notconsider your reasons for not agreeing if they don't come within the scope of the tax laws(for example, if you disagree solely on moral, religious, political, constitutional,conscientious, or similar grounds.)] The following general rules tell you how to appealyour case.

Appeals Within the IRS

Appeals is the administrative appeals office for the IRS. You mayappeal most IRS decisions with your local Appeals Office. The Appeals Office is separatefrom - and independent of - the IRS Office taking the action you disagree with. TheAppeals Office is the only level of administrative appeal within the IRS. Conferences withAppeals Office personnel are held in an informal manner by correspondence, by telephone orat a personal conference. There is no need for you to have representation for an Appealsconference, but if you choose to have a representative, see the requirements underRepresentation.

If you want an Appeals conference, follow the instructions in ourletter to you. Your request will be sent to the Appeals Office to arrange a conference ata convenient time and place. You or your representative should prepare to discuss allissues you don't agree with at the conference. Most differences are settled at this level.

In most instances, you may be eligible to take your case to courtif you don't reach an agreement at your Appeals conference, or if you don't want to appealyour case to the IRS Office of Appeals. See the later section Appeals To The Courts.

Protests

When you request an appeals conference, you may also need to file aformal written protest or a small case request with the office named in our letter to you.Also, see the special appeal request procedures in Publication 1660, Collection AppealRights, if you disagree with lien, levy, seizure, or denial or termination of aninstallment agreement.

You need to file a written protest:

• In all employee plan and exempt organization cases without regard to the dollar amount at issue.
• In all partnership and S corporation cases without regard to the dollar amount at issue.
• In all other cases, unless you qualify for the small case request procedure, or other special appeal procedures such as requesting Appeals consideration of liens, levies, seizures, or installment agreements. See Publication 1660.

How to prepare a protest:

When a protest is required, send it within the time limitspecified in the letter you received. luxury hotels in Palma de MallorcaInclude in your protest:

1) Your name and address, and a daytime telephone number,
2) A statement that you want to appeal the IRS findings to the Appeals Office,
3) A copy of the letter showing the proposed changes and findings you don't agree with (or the date and symbols from the letter),
4) The tax periods or years involved,
5) A list of the changes that you don't agree with, and why you don't agree.
6) The facts supporting your position on any issue that you don't agree with,
7) The law or authority, if any, on which you are relying.
8) You must sign the written protest, stating that it is true, under the penalties of perjury as follows:

"Under the penalties of perjury, I declare that includingany accompanying documents, and, to the best of my knowledge and belief, they are true,correct, and complete."

If your representative prepares and signs the protest for you, heor she must substitute a declaration stating:

1) That he or she submitted the protest and accompanying documents and
ERROR MSG 2) Whether he or she knows personally that the facts stated in the protest and accompanying documents are true and correct.

We urge you to provide as much information as you can, as this willhelp us speed up your appeal. This will save you both time and money.

Small Case Request:

If the total amount for any tax period is not more than $25,000, youmay make a small case request instead of filing a formal written protest. In computing thetotal amount, include a proposed increase or decrease in tax (including penalties), orclaimed refund. For an offer in compromise, in calculating the total amount, include totalunpaid tax, penalty and interest due. For a small case request, follow the instructions inour letter to you by: sending a letter requesting Appeals consideration, indicating thechanges you don't agree with, and the reasons why you don't agree.

Representation

You may represent yourself at your appeals conference, or you mayhave an attorney, certified public accountant, or an individual enrolled to practicebefore the IRS represent you. Your representative must be qualified to practice before theIRS. If you want your representative to appear without you, you must provide a properlycompleted power of attorney to the IRS before the representative can receive or inspectconfidential information. Form 2848, Power ofAttorney and Declaration of Representative, or any other properly written power ofattorney or authorization may be used for this.

Important References

Publication 1660, Collection Appeal Rights
Form2848, Power of Attorney and Declaration ofRepresentative
Publication 5, Your Appeal Rightsand How to Prepare a Protest if You Don't Agree
Publication 1, Your Rights as a Taxpayer