IRS Appeals Attorney in Huntsville, AL
Challenging IRS Audit Results, Tax Assessments & Penalties
If you disagree with the results of an IRS audit or a proposed tax assessment, you may have the right to appeal. The IRS Office of Appeals is designed to resolve tax disputes without going to court, but the process can be technical and deadline-driven.
At Bowman Law Firm, attorney and CPA Gene Mitchell Bowman represents individuals and businesses in Huntsville, Madison County, and across North Alabama in IRS appeals, audit reconsiderations, and collection hearings
When Should You Consider an IRS Appeal?
You may benefit from an appeal if:
- An audit increased your tax and you disagree with the IRS findings
- You received a 30-day letter or Notice of Deficiency
- The IRS disallowed deductions, credits, or expenses you believe are valid
- Penalty abatement was denied or penalties are excessive
- The IRS has proposed or taken a lien, levy, wage garnishment, or seizure
- An installment agreement or Offer in Compromise was rejected
We review your tax transcripts, audit file, and financial situation to determine whether an appeal or audit reconsideration can improve your outcome.
Types of IRS Appeals We Handle
Appeals After an IRS Audit
If you received a 30-day letter or proposed changes after an audit, you typically have the right to request review by the IRS Office of Appeals.
We:
- Identify factual and legal issues in dispute
- Prepare a written protest explaining your position
- Assemble supporting documentation
- Represent you in appeals conferences and negotiations
Appeals of Penalties
We handle appeals involving:
- Failure-to-file and failure-to-pay penalties
- Accuracy-related penalties
- Information return penalties
- Denied **reasonable cause** or **first-time abatement** requests
We build a record showing why penalties should be reduced or removed.
Collection Appeals & Hearings
If the IRS filed or plans to file a lien or levy, or intends to garnish wages:
- Collection Due Process (CDP) hearings
- Equivalent hearings
- Appeals of rejected installment agreements or Offers in Compromise
These proceedings can pause enforcement while we negotiate relief such as:
- Monthly installment agreements
- Currently Not Collectible (CNC) status
- Revised Offers in Compromise
- Adjusted collection terms
Audit Reconsideration: A Second Look at an Old Audit
If you missed the chance to appeal an audit result or did not have complete documentation at the time, audit reconsideration may be an option.
You may qualify if:
- You never received the original audit notice
- You disagree with the audit but did not appeal in time
- You now have new records proving your position
- The IRS has assessed tax you believe is incorrect.
We reconstruct your file, assemble supporting documentation, and request that the IRS reopen and reconsider the prior assessment.
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Our Approach to IRS Appeals
- Attorney with CPA Experience: You receive both legal advocacy and detailed tax analysis
- Focused Issues: We define and narrow the matters in dispute
- Documentation First: We build a clear, organized package before contacting Appeals
- Settlement-Oriented: We look for practical resolutions that avoid litigation when possible
- Appeals & Beyond: If necessary, we coordinate with U.S. Tax Court counsel for further review
Coordination with IRS Audits & Collections
Many appeals grow out of an IRS audit or collection case. Bowman Law Firm can coordinate your appeals strategy with:
- Ongoing or prior IRS audits
- IRS collections (liens, levies, garnishments)
- Offers in Compromise and other resolution options
- State-level actions with the Alabama Department of Revenue
If you already have an audit or collection matter pending, we evaluate whether an appeal can improve your position and timing.
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Frequently Asked Questions: IRS Appeals
How much time do I have to appeal an IRS decision?
Deadlines are strict. Some appeals must be filed within 30 days of a proposed adjustment, and a Notice of Deficiency normally carries a 90-day deadline to petition U.S. Tax Court. It is important to contact a tax professional as soon as you receive an IRS letter.
Can I appeal an audit if I already signed paperwork?
Sometimes. It depends on what you signed, how long ago, and whether new information is available. In certain cases, audit reconsideration or other relief may still be possible.
Do I have to appear in person for an IRS appeal?
Not always. Many appeals are handled by phone or video conference. We can conduct most communications with the IRS on your behalf.
Is IRS Appeals independent from the audit division?
The IRS Office of Appeals is separate from examination and collection divisions and is intended to provide an impartial review. Having organized documentation and clear arguments is critical to success.
Can an appeal reduce penalties or stop enforced collection?
Yes, in many cases appeals can result in reduced penalties or alternative payment arrangements, and certain appeals—such as Collection Due Process hearings—can temporarily halt levies and garnishments while your case is reviewed.
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Service Area
We represent taxpayers in:
- Huntsville
- Madison County
- Decatur
- Athens
- Surrounding communities in North Alabama.
Contact an IRS Appeals Attorney in Huntsville.
If you disagree with an IRS audit result, tax assessment, penalty, or collection action, you may have options.
Contact Bowman Law Firm to discuss IRS appeals, audit reconsideration, or collection due process hearings.
📍 200 Randolph Avenue SE, Huntsville, AL 35801
📞 (256) 539-9850
🌐 www.bowmanlawfirm.net