IA 112: Appellate Review

Overview
Curriculum
Instructor
Reviews

Instructor: Attorney Bob Schaller
Lectures: 3
Quizzes: 1

Categories: Appellate Review, Installment Agreements

Appellate Review.

The Tax Code requires the IRS to conduct an “independent administrative review” before the rejection of an installment agreement is communicated to the taxpayer. 26 U.S.C. § 7122(e). Although the intention to recommend rejection should be relayed to the taxpayer, actual rejection of a proposed agreement must not be conveyed to a taxpayer prior to independent administrative review, and enforcement action may not be taken while installment agreements are pending. IRM § 5.14.1.4(11) (09-19-2014). No levy may be issued until after 45 days have passed since the IRS communicates to the taxpayer that installment agreement request was rejected. IRM § 5.14.9.7(13)(d) (12-18-2017); but see 26 U.S.C. § 6331(k) (30 days after rejection).

Overview 0/1
- Lecture 1.1
  Overview of a Taxpayer’s Appellate Rights
  10 minutes
  10m
Independent Administrative Review 0/1
- Lecture 2.1
  IRS’ Independent Administrative Review Before Rejecting Installment Agreement Request
  30 minutes
  30m
Appealing Rejection of Installment Agreement Request 0/1
- Lecture 3.1
  Taxpayer’s Right to Appeal the Rejection of an Installment Agreement Request
  15 minutes
  15m
Quiz 0/1
- Quiz 4.1
  Test Your Knowledge of a Taxpayer’s Appellate Rights
  10 questions60 minutesFinal
  1h0m

Attorney Bob Schaller

OIC Tax Attorney & Registered CPA

Bob has been practicing law for over 35 years and brings his skills and insight into every course. He is admitted to practice before the United States Supreme Court, the United States Tax Court, the United States Court of Appeals for the Seventh Circuit, and the Illinois Supreme Court. He authored the 654-page book titled "IRS Offer in Compromise, Installment Agreements & Innocent Spouse Relief: A Treatise for Tax Professionals."

Reviews

Tax Law
Appellate Review

This course teaches tax professionals that the Tax Code requires the IRS to conduct an “independent administrative review” before the rejection of an installment agreement is communicated to the taxpayer. Although the intention to recommend rejection should be relayed to the taxpayer, actual rejection of a proposed agreement must not be conveyed to a taxpayer prior to independent administrative review, and enforcement action may not be taken while installment agreements are pending.