IRS Appeals
The IRS Independent Office of Appeals resolves disputes with the IRS without going to court. Stone Tax Counsel represents clients before Appeals when an audit ends in disagreement and when a Tax Court case is sent to Appeals before trial.
Matters We Handle
Disputes over proposed adjustments at the end of an audit
Penalty disputes
Partnership audit disputes
Tax Court cases referred to Appeals before trial
Cases involving IRS settlement programs and enforcement campaigns
Our Approach
Every Appeals case is prepared as if it will be tried. The written protest lays out the facts, the law, and the weaknesses in the IRS's position, and the record built at Appeals carries forward into the Tax Court if the case does not resolve. Appeals is not always the right path, and for some issues going directly to the Tax Court is the better choice.
Experience
William A. Stone III has represented clients in Appeals conferences in cases both before and after a Tax Court filing, and has written for Tax Notes on Appeals' independence and IRS settlement programs.
Contact Stone Tax Counsel
To discuss a matter, complete the form below or call (404) 494-0918. The firm works with clients nationwide.