An examination went wrong. A protest that argues the law, within the 30-day period in the letter.

Describe what the IRS proposed and why it is wrong. CitedTax drafts the protest in the form Publication 5 requires, argues each item from the Code and the regulations, contests the penalty on its own grounds, and, where a notice of deficiency or a levy notice is in play, writes the Tax Court assignments of error or the collection due process request.

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At a glance

Cost: 1 credit ($25)
You provide: the letter or notice (PDF, optional), the facts, and what the client says is wrong
You receive: a written protest in your firm's name with every disputed item argued and cited, the penalties-of-perjury declaration, and the Tax Court or CDP section where the notice calls for it
Turnaround: about thirty minutes

Credits never expire. A request that fails on our side returns its credits automatically.

What you get

Three things to count on.

The right vehicle

A 30-day letter gets a protest to Appeals; a notice of deficiency gets the Tax Court petition inside 90 days; a lien or levy notice gets the Form 12153 request inside 30 days, each with its deadline tested.

Every item argued and cited

Each disputed adjustment carries the facts, the Code section or regulation, and the conclusion, through the same citation gate as the review papers.

Penalties contested on their own grounds

Reasonable cause, substantial authority and the supervisory approval requirement are each tested against the facts.

A worked example

A 30-day letter disallowing management fees and recharacterizing S corporation distributions as wages

The protest shows the fees were arm's-length payments for real services, applies the compensation surveys to the dentist's actual hours, contests the accuracy-related penalty for reasonable cause and substantial authority, and asks for an Appeals conference.

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