The focus of our practice is civil and criminal taxpayer representation, as well as bankruptcy and commercial litigation. We frequently have New Haven taxpayers come to our office with a federal tax debt they do not believe they owe to the IRS.
We can tell you that there are many opportunities to challenge a federal tax liability with the IRS, even after the opportunity to appeal has come and gone.
Opportunities for challenging a tax liability include:
- Filing a timely appeal with the IRS within 30 days after the proposed assessment;
- Filing a protest with the United States Tax Court within 90 days after the Notice of Deficiency is received (referred to as the “90 Day Letter”);
- Filing a Doubt as to Liability offer; and
- Requesting Audit Reconsideration.
The keys to both a Doubt as to Liability offer and an audit reconsideration request is proving to the IRS that you do not owe the tax assessed. Therefore, providing documentation to the IRS to confirm the taxpayer does not owe the money is critical to successfully challenging the assessed tax.
Hence, even though the IRS has assessed the tax and the taxpayer missed his or her appeal, the game is not over yet. In addition, by filing either a Doubt as to Liability offer or an audit reconsideration request, the taxpayer will get the Collection activity by the IRS to cease until the matter has been considered.
If you would like to discuss challenging and resolving an outstanding IRS tax assessment in Connecticut, please feel free to contact me at (860) 494-4786 or by email at egreen@convicerpercy.com
Eric L. Green, Esq.
Convicer, Percy & Green, LLP
Glastonbury, CT w New Haven, CT w Stamford, CT
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