
- 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).
Video Overview
Overview of Appellate Rights
Independent Administrative Review
Appellate Rights Following Collection Due Process Determination
Appellate Rights Following a Non-Collection Due Process Determination
IRS Office of Appeals
IRS Office of Appeals' Jurisdiction & Function
Appealable & Non-Appealable Decisions
30-Day Appeal Deadline
Appeal Application Process
Appellate Issues
Appeals Referral Investigation
Sustaining Offer Rejection
Conference and Practice Requirements
Re-Opening a Rejected Offer Previously Sustained on Appeal
Taxpayer Compliance
Ex Parte Communications are Prohibited
Quiz
Reviews
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).