I have a client ( I have posted info about this client before) who owes the IRS over $90,000. Half for additional tax liability and half for penalties / interest.
One of the options that is listed if we do not agree with the outcome is to request a conference with an Appeals Officer. Has anyone ever done this? And, if yes did it help?
We are not arguing the tax liability, but just the additional penalties.
This is the first time I have had an audit come out this way (just in case anyone is wondering I didn’t do the return, just helped with the audit), and I know that the client cannot pay.
My other question is should the client sign off, and set up a payment plan. And after that part is done start with the OIC paperwork?
I plan on sending in a letter rebutting some of the auditor’s assumption along with copies to back up my point, and I hope that they might reduce the penalty. But the part that I am not sure about is the signing of the proposed amounts due. I believe that since I am sending in the letter and additional documentation that I don’t need to have the client sign. And, if he were to sign it would appear that he is agreeing to the deterimination.
Any suggestions would be appreciated.
Thanks,
Cris

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