US TAX COURT AND
IRS TAX APPEALS
The United States Tax Court is a federal court established to resolve disputes between taxpayers and the IRS. 
IRS Independent Office of Appeals: The most common Appeals cases pertain to:
Collection Appeals – IRS Collection-source cases such as Collection Due Process (CDP) hearing, offer in compromise, Collection Appeals Program (CAP), and Trust Fund Recovery Program cases.
Examination Appeals: Completed exams (audits) are appealed when the taxpayer does not agree with the proposed audit findings.
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