IRS Appeals and Business Collection Defense Attorney

The IRS Appeals process for businesses is an independent administrative review that allows businesses to challenge IRS audit findings or collection actions without going to court. After the IRS proposes adjustments or takes collection action, your representatives at Booth P.C. submit a formal protest or request for review to IRS Appeals, where an Appeals officer, who is separate from the examining or collection function, evaluates the facts, applicable law, and the hazards of litigation for both sides. At Booth P.C., we use this process to negotiate reductions in proposed tax, penalties, or interest, or to secure more favorable collection terms, often resolving disputes more efficiently and cost-effectively while protecting your business’s rights and cash flow.

Businesses can challenge IRS collection actions in a several ways, including procedural challenges and legal challenges. At Booth P.C. we guide you through your options strategically to protect your businesses’ operations and cash flow. Depending on the situation, we can request a Collection Due Process (CDP) hearing or an Equivalent Hearing to dispute liens or levies, appeal collection decisions to IRS Appeals, and propose alternative resolutions such as installment agreements, offers in compromise, or currently not collectible status. At Booth P.C., our role is to stop or pause enforcement where possible, force an independent review of the IRS’s actions, negotiate a solution that resolves the liability, and litigate in Court on your behalf when necessary while minimizing disruption to your business.

A Collection Due Process (CDP) hearing for businesses is a formal administrative appeals process that allows your business to challenge or resolve IRS collection actions, such as the filing of a federal tax lien or the issuance of a levy, before or shortly after they take effect. By timely requesting a CDP hearing, Booth P.C. can generally pause collection activity while an independent IRS Appeals officer reviews whether the IRS followed the law, considers collection alternatives like installment agreements or offers in compromise, and evaluates whether the proposed collection action is more intrusive than necessary. At Booth P.C., our role is to protect your business by stopping enforcement, presenting the strongest possible resolution strategy, and preserving your right to further review, including appeal to the U.S. Tax Court if the determination is unfavorable.

The Collection Appeals Program (CAP) allows businesses to quickly challenge certain IRS collection actions, such as levies, liens, seizures, or the termination of an installment agreement, without the strict timing and formalities of a Collection Due Process hearing. Under CAP, Booth P.C. requests an expedited review by IRS Appeals, often while the issue is still being developled by the IRS, and present arguments focused on whether the collection action is appropriate and whether a better alternative exists. While CAP does not provide the same automatic collection suspension or Tax Court appeal rights as CDP, at Booth P.C. it is a powerful tool we use to resolve urgent collection

A business can go to Tax Court after IRS Appeals when the IRS issues a Notice of determination that gives statutory court rights, and the timing of depends on the type of case. If the dispute involves an audit or proposed deficiency, the IRS must issue a Notice of Deficiency, and you then have 90 days to file a Tax Court petition before any tax is assessed or collected. If the case involves collection actions resolved through a Collection Due Process (CDP) hearing, you have 30 days from the Notice of Determination to petition the Tax Court, and collection generally remains suspended while the case is pending. At Booth P.C. our role is to track these deadlines precisely, determine whether Tax Court is the best next step, and file timely to preserve your business’s rights and leverage.

Businesses should hire an attorney for IRS Appeals defense because successful interactions with IRS Appeals require strategy, legal positioning, and negotiation skills. At Booth P.C., we understand how Appeals officers evaluate cases based on law, facts, and litigation risk, and we know how to present your position in a way that highlights weaknesses in the IRS’s case while protecting your business from unnecessary and costly mistakes and assessments and/or collection actions. By handling communications, drafting persuasive protests, and negotiating from a position of experience, Booth P.C. works to reduce tax, abate penalties, secure favorable collection terms, and preserve your rights, often resolving disputes efficiently without the expense and disruption of court proceedings.

Yes, a skilled tax attorney can often stop or prevent an IRS tax lien or levy against your business by acting quickly and using the IRS’s administrative appeal and collection procedures. At Booth P.C., when we represent you, we can request a Collection Due Process (CDP) hearing or use the Collection Appeals Program (CAP) to pause or challenge enforcement, negotiate collection alternatives such as an installment agreement or offer in compromise, and argue that the lien or levy is inappropriate or more intrusive than necessary. At Booth P.C., we also work to secure collection holds while matters are under review and, when needed, escalate the case to IRS Appeals or Tax Court, all with the goal of protecting your business’s assets, cash flow, and ability to operate.

Businesses can appeal a wide range of IRS disputes, and at Booth P.C. we use the Appeals process strategically to challenge both audit and collection decisions. Issues that IRS Appeals considers include audit adjustments to income, deductions, credits, accounting methods, and payroll taxes; proposed penalties and interest assessments; denials or terminations of installment agreements or offers in compromise; and collection actions such as tax liens and levies through Collection Due Process or CAP. At Booth P.C., our role is to identify which disputes are eligible for appeal, choose the most effective appeals path, and present a well-supported case to an independent Appeals officer to seek a fair and efficient resolution while protecting your business’s financial stability.

The length of the IRS Appeals process for businesses varies depending on the complexity of the case, the type of dispute, and the Appeals officer’s workload, but the typical range is 6-18 months from start to resolution. Straightforward collection appeals or penalty disputes may be resolved more quickly, while complex audit appeals involving multiple issues, large dollar amounts, or extensive documentation can take longer. When Booth P.C. represents your business, we manage the timeline by submitting a complete and well-supported appeal, responding promptly to Appeals requests, and pushing for efficient resolution, all while seeking to keep collection activity on hold and minimizing disruption to your operations during the process.

Booth P.C. helps businesses with IRS collection disputes by stepping in immediately to protect cash flow, assets, and ongoing operations while pursuing the most effective resolution strategy available under the law. We take over communications with the IRS, stop or pause liens and levies through Collection Due Process hearings, CAP appeals, and negotiated collection holds, and advocate for workable solutions such as installment agreements, offers in compromise, or currently not collectible status. By leveraging IRS Appeals and, when necessary, Tax Court review, we challenge improper collection actions, negotiate from a position of experience, and guide your business toward a resolution that resolves the tax debt without jeopardizing its ability to operate and grow. Contact Booth P.C. today for a free consultation.