EPISODE · May 6, 2026 · 13 MIN
What Happens During an IRS Appeal and When It Makes Sense
from The Legal Podcast Network
Episode Summary: Lawrence T. Ullmann discusses the purpose of IRS appeals, the role of the appeals office, eligibility for appeals, factors considered in appeal reviews, and the importance of hazards of litigation in decision-making, offering insights into resolving tax issues efficiently. Key Timestamps: 00:00 – Introduction to the episode on IRS appeals 00:44 – Purpose of the IRS Appeals Office 02:03 – How appeals differ from the examination/audit division 03:10 – When a taxpayer can request an appeal after an audit 04:00 – Factors the appeals office considers 04:50 – Hazards of litigation and how it affects settlements 06:30 – General example of a case moving from audit to appeals 09:10 – When filing an appeal may not be the best strategy 10:30 – How formal the appeals process is and what to expect 11:50 – What makes an appeal more likely to resolve efficiently 12:30 – Closing remarks and contact information About the Show: *Tax Problems Explained* offers valuable insights into navigating tax issues from the perspectives of an attorney, a CPA, and a former IRS agent, providing expertise in understanding and resolving complex tax problems efficiently.
What this episode covers
Episode Summary: Lawrence T. Ullmann discusses the purpose of IRS appeals, the role of the appeals office, eligibility for appeals, factors considered in appeal reviews, and the importance of hazards of litigation in decision-making, offering insights into resolving tax issues efficiently. Key Timestamps:00:00 – Introduction to the episode on IRS appeals00:44 – Purpose of the IRS Appeals Office02:03 – How appeals differ from the examination/audit division03:10 – When a taxpayer can request an appeal after an audit04:00 – Factors the appeals office considers04:50 – Hazards of litigation and how it affects settlements06:30 – General example of a case moving from audit to appeals09:10 – When filing an appeal may not be the best strategy10:30 – How formal the appeals process is and what to expect11:50 – What makes an appeal more likely to resolve efficiently12:30 – Closing remarks and contact information About the Show:*Tax Problems Explained* offers valuable insights into navigating tax issues from the perspectives of an attorney, a CPA, and a former IRS agent, providing expertise in understanding and resolving complex tax problems efficiently.
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What Happens During an IRS Appeal and When It Makes Sense
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