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IRS Disputes & Appeals in Palm Beach County
Former IRS Revenue Agent Now Fighting for Palm Beach County Taxpayers
An IRS decision isn’t final. Taxpayers in Palm Beach County have the right to dispute audit findings, proposed tax deficiencies, rejected offers in compromise, filed tax liens, and levy actions before paying a single dollar of a contested amount. Our guiding principle is that any tax problem can have a positive resolution when approached with full understanding of the taxpayer’s situation, persistence, and legal knowledge.
We represent Palm Beach County taxpayers in IRS disputes and appeals across a range of case types, including:
Call or contact us online to speak with an IRS tax attorney in Palm Beach County today!
How the IRS Appeals Process Works
After an IRS examination, the agency typically issues a 30-day letter proposing changes and giving the taxpayer 30 days to file a protest with the IRS Independent Office of Appeals. That office operates separately from the examination team and reviews disputed decisions independently. Appeals officers can weigh the risk of litigation when evaluating a case, which means the appeals stage may produce meaningful reductions in a proposed deficiency without entering a courtroom.
If the administrative appeals process doesn’t resolve the dispute, or if the taxpayer doesn’t respond to the 30-day letter, the IRS issues a Notice of Deficiency, commonly called a 90-day letter. At that point, the taxpayer may petition the U.S. Tax Court without paying the contested tax first. Tax Court is one of the few venues where a federal tax dispute can be heard before payment, making it a critical option to preserve.
Time limits govern every stage of this process. Missing a deadline can forfeit the right to appeal entirely or require payment of the full contested amount before any challenge is possible. Acting early can keep more options open and may reduce the cost of resolution.
Our knowledge of IRS processes gives our clients multiple channels through which to contest an IRS decision:
A formal protest letter contesting the IRS determination
A full review of your financial statements
Freedom of Information Act (FOIA) requests to obtain IRS records relevant to your case
Michael K. Miller spent his early career as an IRS Revenue Agent in Washington, D.C., conducting audits of individual tax returns for the Internal Revenue Service. That experience, combined with his background as a licensed CPA focused exclusively on tax matters, gives our clients insight into IRS disputes: we understand how the agency builds its cases because we have built them.
Miller entered private practice in 1989 and has devoted more than 35 years to tax law. He has been a member in good standing of the Florida Bar since 1989 and is admitted to practice before the United States Tax Court. Martindale-Hubbell has recognized him with an AV Preeminent rating, awarded to fewer than 10% of attorneys nationally, reflecting the highest standard for legal ability and ethical conduct. In IRS disputes and appeals, that kind of judgment and professional standing matters.
We offer a free initial consultation to every new client. Each case gets a cost-effective strategy tailored to the taxpayer’s specific situation, not a one-size approach.
IRS Appeal Deadlines Won’t Wait
The window to act narrows quickly once the IRS issues a proposed adjustment or a Notice of Deficiency. The sooner you engage an IRS attorney in Palm Beach County, the more options may remain available to you.
What to Expect from the IRS Independent Office of Appeals
The IRS Independent Office of Appeals operates separately from the examination and collection functions of the agency. Its purpose is to resolve tax disputes impartially, and its officers weigh the merits of the government’s position against the risk that a court might rule differently. That risk-of-litigation analysis is what gives the appeals stage settlement potential: a strong factual record and a well-prepared protest can affect the analysis in a taxpayer’s favor.
Cases that commonly reach the appeals stage include disputed audit findings, rejected installment agreement requests, denied penalty abatement claims, and contested lien or levy actions. The process applies to both individuals and businesses, and the scope of what an appeals officer can address is broad.
Possible Outcomes at the Appeals Stage
Taxpayers who successfully navigate the IRS appeals process may see reductions in proposed tax deficiencies, removal or reduction of penalties, or release of liens and levies. Industry data has historically indicated that a substantial share of taxpayer appeals produce outcomes more favorable than the original IRS determination, though results depend on the specific facts, the documentation presented, and the legal arguments raised. No outcome is guaranteed.
When Appeals Don’t Resolve the Dispute
If the IRS Independent Office of Appeals doesn’t produce a satisfactory result, the taxpayer retains the right to petition the U.S. Tax Court, file a suit in the U.S. Court of Federal Claims, or bring an action in a U.S. District Court. Each forum has different procedural requirements, filing deadlines, and payment rules. The U.S. Tax Court remains the most commonly used forum for disputed tax deficiencies because it allows the taxpayer to contest the amount before paying it. Choosing the right forum depends on the nature of the dispute, the amounts involved, and the taxpayer’s overall legal strategy.
“My experience working with Mr.Michael Miller was fantastic.”
My experience working with Mr.Michael Miller was fantastic. His expertise made navigating an unfamiliar and potentially intimidating subject matter possible. He was easy to contact and communicate with through out my case, I appreciated his efficiency , promptness and professionalism all while being friendly and personable. I have already recommended him to friends and wanted to spread the word here as well.
