IRS Tax Audit Appeals

After the Revenue Agent writes a final “Revenue Agent Report”, you have either 30 days or 60 days (depending on the type of tax return examination) within which to file a Protest to the IRS Office of Appeals. After that time expires, the next course of action is usually a Petition in the United States Tax Court, so the deadline for filing a Protest should be taken seriously.

A properly-prepared Protest not only sets forth the items of disagreement with the Revenue Agent, but also contains a detailed analysis of the legal basis for the taxpayer’s arguments disputing the findings of the Revenue Agent. Appeals Officers are frequently trained in tax law, and have access to IRS lawyers who can help them sift through the nuances of tax law, in order to decide whether the taxpayer’s arguments have strength, or any merit at all. It is very important to have an experienced tax lawyer on your side through this process.

David A. Sprecace has more than 23 years of experience preparing Protests to the IRS Office of Appeals, meeting with Appeals Officers, and proceeding to Tax Court if necessary. Call 303-454-8260 or email Dave at to set up a phone consultation.


Colorado Office
600 17th St #2800s

Denver, CO 80202

Client Reviews

Dave has ridden to our rescue on many occasions. It’s not that I try to get in trouble but Dave is always there to bail me out. Dave went toe-to-toe with the IRS over a several year legal battle. Nothing like having a...

- Russell and Lisa P.

My business partner and I hired Dave to represent us with an IRS tax audit of our company and individual tax returns. There were other family members and other businesses involved, and the IRS initially wanted more than...

- Mark M.

I called Dave to help me file several years of income tax returns. After the returns were filed, Dave filed an Offer in Compromise to get rid of the old taxes. The IRS accepted a small fraction of the original amount...

- Mike W.

When I needed to buy out my business partner, Dave told me of the possible pitfalls with the Operating Agreement, walked me through the entire process, helped me value the company, and make an offer. I was able to keep...

- Yvonne A.

Contact Us

Fill out the contact form or call us at (303) 454-8260 to schedule your consultation.

Leave Us a Message