An adverse IRS determination is not the end of the road; it’s often the point where experienced practitioners gain the most leverage. With tens of thousands of cases flowing through the IRS Independent Office of Appeals each year, knowing how to strategically position a case for Appeals can significantly impact outcomes for your clients.
This session moves beyond procedural mechanics to focus on how to use Appeals as a deliberate and effective tool in resolving complex tax controversies. You’ll explore when an appeal strengthens your client’s position, and when it may not, while developing a sharper understanding of how to evaluate risk and timing, and potential outcomes across examination, collection and penalty matters.
We’ll examine how Appeals officers assess hazards of litigation, weigh facts and legal arguments, and approach settlement decisions. You’ll gain insight into how to frame issues, present arguments and make strategic choices that align with the appeals process.
Designed for experienced practitioners, this session emphasizes practical judgment and real-world application, equipping you to approach IRS disputes with stronger strategic positioning and potentially more effective client outcomes.
Objectives
Upon completion of this session, you will be able to:
- Evaluate when to pursue an appeal versus alternative resolution strategies by assessing risk, timing and potential outcomes
- Apply Appeals procedures and taxpayer rights across examination, collection and penalty matters to effectively position a case
- Analyze how Appeals officers use hazards of litigation and other factors to reach settlement decisions and align arguments accordingly
- Develop strategic approaches to framing issues and presenting cases
