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APPEALS OF COLLECTION ACTION

Appealing the Excercise of Collection Action

If you receive notice or warning of enforced IRS collection actions or are denied the benefit of a specific resolution option, then you have the right to appeal to the IRS Office of Appeals.

You also have the right to secure qualified tax representation to steer you through this complicated process and help you attain the most favorable resolution. The attorneys at Tax Muscle will file your appeal to stop an IRS lien, seizure, or levy, or contest the denial of a tax resolution option that you otherwise seek, and follow up through the necessary channels.

The actions and denials that can be appealed include:

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Federal tax lien

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Seizure and sale of property

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Intent to levy wages, retirement accounts, bank accounts, accounts receivable, etc.

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Rejection, termination, or proposed termination of an installment agreement

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Rejected Offer in Compromise

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Proposed Trust Fund Recovery Penalty

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Denied Trust Fund Recovery Penalty Claim

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Denied request to abate penalties (such as late filing, late payment, or deposit penalties)

There are two primary appeals procedures available, depending on the IRS notice you received or the collection actions being threatened: 1) Collection Due Process (CDP), and 2) Collection Appeals Program (CAP). You have the right to a hearing through both of these procedures, but are required to make your request in a timely manner. If you prefer, Tax Muscle can represent you in your absence so that you can tend to your everyday affairs while we pursue a favorable outcome in your appeal. Our skilled tax professionals have helped numerous people such as yourself and will direct you through this process to ensure that you obtain the most beneficial resolution possible.

Appeals

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