
- Instructor: Attorney Bob Schaller
- Lectures: 17
- Quizzes: 1
Appellate Rights Relating to OICs.
This course discusses appellate rights in the Offer in Compromise context. Appellate rights are better understood when segregated into three issues: (1) appellate rights relating to a pre-rejection “independent administrative review”; (2) appellate rights following a collection due process determination (i.e. offer made as part of CDP hearing); and (3) appellate rights following a non-collection due process determination (i.e. stand-alone offer).
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Video Overview
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Overview of Appellate Rights
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Independent Administrative Review
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Appellate Rights Following Collection Due Process Determination
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Appellate Rights Following a Non-Collection Due Process Determination
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IRS Office of Appeals
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IRS Office of Appeals' Jurisdiction & Function
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Appealable & Non-Appealable Decisions
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30-Day Appeal Deadline
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Appeal Application Process
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Appellate Issues
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Appeals Referral Investigation
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Sustaining Offer Rejection
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Conference and Practice Requirements
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Re-Opening a Rejected Offer Previously Sustained on Appeal
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Taxpayer Compliance
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Ex Parte Communications are Prohibited
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Quiz
Reviews
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Tax Law
It is important for all tax professionals to know a taxpayer's appellate rights in the Offer in Compromise context. The course explained that appellate rights are better understood when segregated into three issues: (1) appellate rights relating to a pre-rejection “independent administrative review”; (2) appellate rights following a collection due process determination (i.e. offer made as part of CDP hearing); and (3) appellate rights following a non-collection due process determination (i.e. stand-alone offer).