Twin Cities Administrative Appeals Attorneys
When clients are facing hearings, they also come to us for help. As lawyers, we will represent taxpayers at hearings or, if necessary, file a lawsuit in federal court on their behalf.
A CDP hearing, also known as a Collection Due Process Hearing, could be your last best chance to settle a tax dispute with the IRS without resorting to tax litigation. Before issuing a levy, the IRS must first issue a Notice of Intent to Levy and Right to Request a Hearing. If you request a CDP hearing within 30 days of receiving it, the IRS will not levy your account until you have had a chance to appeal. We need as much time as possible to present your case in the best possible light, so please contact us as soon as possible after receiving this note.
The Notice of Intent to Levy and Right to Request a Hearing is usually mailed to your last known address by certified or registered mail with return receipt requested. The IRS may submit the Notice of Intent to Levy and Right to Request a Hearing in person or leave it at your home or place of business instead of mailing it certified or registered mail.
To protect your rights and collaborate with your tax team to put together the best strategy for you, it’s important to retain legal counsel before the deadline.
Federal Court Appeals
Depending on the facts and applicable law in a specific case, the United States Tax Court, the United States District Court, or the United States Court of Claims can be used to resolve a tax dispute. As lawyers, we will advise you on whether filing a lawsuit in one of the federal courts is likely to result in a favorable outcome in your case.
The United States Tax Court is a judicial forum where citizens who have been affected by tax deficiencies determined by the Commissioner of Internal Revenue can appeal them before the contested sums are charged. The United States District Court has the authority to hold civil trials occurring under the United States Constitution, statutes, and treaties, including the tax laws of the United States. The District of Minnesota is the proper district for Minnesota citizens. The United States Court of Federal Claims has jurisdiction over a broad variety of government-related claims, including tax refund lawsuits. The United States Court of Federal Claims has jurisdiction over a broad variety of government-related claims, including tax refund lawsuits.