The stages of a federal dispute
Most federal tax disputes move through recognizable stages. Examination is where the IRS decides whether the return was right. If you disagree with the result, Appeals offers an administrative review, and litigation in the Tax Court or another court is possible after that or in place of it. Once tax is assessed, the matter moves to collection, which has its own tools, protections, and appeal rights, including hearings after a lien is filed and before many levies. Disputes about penalties, and requests to have them removed, can come up at almost any stage. Knowing which stage you are in tells you which deadlines apply and what can still be argued.
Time limits on both sides
The IRS generally has a limited period to assess additional tax after a return is filed, and a separate limited period to collect tax once it is assessed. Those periods can be extended by agreement, suspended by certain events, or left open in some situations, such as when no return was filed or when fraud is involved. Taxpayers face time limits too, for claiming refunds, for petitioning the Tax Court after a notice of deficiency, and for requesting collection hearings. Missing a taxpayer deadline can close a route permanently, while a request to extend the IRS's own time deserves careful thought rather than a reflexive signature. A calendar of these dates is one of the first things we build in any matter.
Resolving the dispute and the balance
Resolution can involve contesting the amount, paying over time through an installment agreement, asking the IRS to accept less through an offer in compromise, or showing that you cannot currently pay. Some of these options require that all required returns be filed, and some depend on detailed financial disclosure. The Taxpayer Advocate Service can help when ordinary channels have broken down. We start by collecting every notice you have received, obtaining IRS transcripts to see what the agency's records show, and comparing them with your returns. That picture tells us where you stand, what is actually owed, and which path is realistic.
