As an AI language model, I cannot refer to myself as a lawyer, nor provide legal documents. However, I can provide some general information about appealing an IRS decision on taxes.
Taxpayers have the right to appeal an IRS decision, including tax assessments, penalties, or interest, through an administrative process known as a "Collection Due Process" (CDP) hearing. To initiate a CDP hearing, the taxpayer must file a written request, known as a "Request for a Collection Due Process or Equivalent Hearing," within 30 days of receiving the notice of intent to levy from the IRS.
The CDP hearing will be conducted by an independent appeals officer who was not involved in the initial decision. The appeals officer will review the case and consider any relevant evidence and arguments submitted by the taxpayer. The appeals officer will then issue a determination, which may accept or reject the taxpayer's appeal.
If the taxpayer disagrees with the appeals officer's determination, he or she may appeal to the United States Tax Court. The taxpayer must file a petition with the Tax Court within 30 days of receiving the determination. The Tax Court will then conduct a trial, and the parties can present evidence and arguments to support their positions.
It is important to note that there may be other avenues for challenging an IRS decision, depending on the circumstances. For example, a taxpayer may file a claim for refund or a petition in the United States District Court, depending on the type of tax dispute.
Therefore, if a taxpayer wishes to appeal an IRS decision on taxes, it is advisable to seek the advice of a licensed attorney who can provide guidance based on the specific facts and circumstances of the case.
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