Tax Appeals

Our objective at M. Robinson & Company, P.C. is always to resolve the dispute as soon as possible, at the lowest level possible, and at the lowest combined cost in tax and professional fees. Therefore, we will typically try to resolve matters with the auditor, if possible. We will then try to reach an agreement or compromise at the appeals level. We will, if necessary, take the next step and appeal an adverse decision to the United States Tax Court or to the Massachusetts Appellate Tax Board.

Government auditors have little discretion and will typically resolve ambiguities against the taxpayer. Appeals officers, however, have greater discretion and will take into account the hazards of a court battle. It follows that a tax appeal may be the next step if we are unable to reach agreement with the auditors.

We have successfully concluded tax appeals with:


The Internal Revenue Service (IRS) Appeals Office

M. Robinson & Company, P.C. represents clients in appeals to the IRS Appeals Office. The principal function of the Appeals Officers is to settle tax cases and to screen cases that do not belong before the U.S. Tax Court. Appeals Officers are typically lawyers with many years of experience. They have the authority to weigh the ambiguities of a particular situation, give taxpayers the benefit of the doubt, and to strike a compromise, something that auditors are not authorized to do.

The Massachusetts Department of Revenue (DOR) Office of Appeals

M. Robinson & Company, P.C. also represents clients in appeals to the Office of Appeals. The principal functions of the Appeals Officers is to meet with taxpayer representatives, develop the facts, research the law and make recommendations to the Settlement Review Board which includes three of the top executives at the Massachusetts Department of Revenue. The Appeals Officers then act as a liaison between taxpayer and a Settlement Review Board. This board makes the final decision in the case.