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Watch our new video to learn about tax appeals!

In this video you’re going to learn about IRS Tax Appeals and, additionally, how Appeals can be used to save yourself from a painful situation with the IRS.

We cover three types of Appeals: Collection Due Process (CDP) Appeals, Equivalent Hearings and, finally, Collection Appeals Process (CAP) Hearings.

A taxpayer’s appeal rights are triggered after receiving a Notice of Federal Tax Lien or a Final Notice of Intent to Levy.

The first type of appeal right that we discuss is the Collection Due Process Hearing (CDP). This is the most powerful type of appeal and offers the most protection and rights to the taxpayer. In addition, a request for a CDP Hearing must be made within 30 days.

The second type of appeal right that we review is the Equivalent Hearing. This offers fewer rights than a CDP Hearing, but it is more flexible in terms of timing.   A taxpayer may request an Equivalent Hearing for up to one year.

The third type of appeal right that we discuss is called Collection Appeals Process (CAP). This is used primarily to untangle administrative errors relating to cases, such as levies issued to the wrong taxpayer.

Lastly, we discuss what an actual Appeal looks like and what you need to know to be successful at an Appeal Hearing.

If you enjoyed this video, and would like to see more content visit our YouTube channel!

To learn more about the services we provide, call our office at 678-235-5460, or visit our Home Page!

Founded by Gary Massey, Massey and Company is a boutique CPA firm in located in Atlanta, Georgia serving the needs of small businesses and their owners.



How Do You Challenge a Tax Bill?

Incorrect tax bills are actually fairly common. Why is this? It is because the IRS is relying on automated systems more and more to deal with taxpayers. For example, 75% of all IRS audits are done by computers. The IRS uses computer systems to create substitutes for tax returns, where they are missing them. As a result of this automation, many Atlanta taxpayers are receiving letters in the mail from the IRS that contain tax bills with incorrect tax amounts.

I hear of folks who write to the IRS about a bad tax assessment, and they experience the frustration of their paperwork getting lost in the system. As a result, bad tax assessments go unchallenged and appeals are not made. Individual taxpayers then find themselves battling with IRS Collections for money that they do not owe. These individuals may even be subject to a tax lien, which makes it nearly impossible to get approved for a mortgage. 

But fear not! Fortunately, there are ways to challenge an IRS tax bill.

1. Request for Audit Reconsideration
   We can get the audit reopened and re-examined.

2. Doubt-as-to-Liability Offer
    This is a type of Offer-in-Compromise that challenges the underlying liability itself.

3. Collection Due Process Hearing (CDP)
    During the hearing, the tax bill can be challenged.

4. Innocent Spouse Relief 
    We ask the IRS to adjust the amount of tax due, by allocating the tax between the spouses or former spouses.

5. File an Amended Return
    If the taxpayer does not receive anything in 6 months, then they can bring a litigation suit.

6. Bankruptcy
The issue can be challenged through bankruptcy

Which of these is the right one for you? The answer depends on an analysis of your facts and circumstances. Gary does this for our clients. If you are facing a tax bill, send me a message to discuss which strategy is right for you.

If you would like to watch our YouTube video on this topic, click here. Feel free to call our office at 678-235-5460 for more information!

Visit our Home Page

Founded by Gary Massey, Massey and Company is a boutique CPA firm in located in Atlanta, Georgia serving the needs of small businesses and their owners.


Audit RatesAccounting Today recently published an article, “Ten Major Trends in IRS Audits,” examining how IRS audit rates have changed over the past several years. This article provides useful information for taxpayers, especially those who own a business.

Audits of Business Entities

Partnerships and S Corporation are less likely to be audited. According to the article, “The IRS continues to struggle to audit S corp and partnership returns. This situation is likely to get worse as the more experienced IRS business auditors continue to retire. Audit rates for S corps and partnerships are both 0.22 percent – or, put another way, one in every 455 passthrough entities were examined in 2018. It is no wonder that the number of S corporations have increased by 38 percent from 2005 to 2018 (3.5 million in 2005 versus 4.85 million in 2018).” This is an important factor to consider when thinking about making an “S election” for your business.

In addition, audit rates have dropped overall in the last decade. “Most taxpayers envision Internal Revenue Service audits as intrusive investigations resulting in criminal sentences. Today, nothing could be farther than the truth. The IRS’s auditing power has been greatly diminished in the past decade. Congress reduced IRS audit resources by 28 percent in the last decade. And audits are down  from 0.9 percent in 2010 to o.5 percent in 2018. In fact, the number of IRS audits in 2018 (991,168) dropped by almost half compared to 2010 (1.735 million).”

Audit Targets

Nevertheless, there are situations where the IRS consistently audits companies or individuals. According to the article, audits are especially popular among the wealthy. “In 2011, one out of every eight taxpayers who earned more than $1 million in income were audited. In 2018, the number dropped to one in every 31 taxpayers. However, those who earn more than $1 million are still among the most popular audit profiles.”

Article References
Accounting Today, “Ten major trends in IRS audits.” By Jim Buttonow. Click here to read the original article.

Founded by Gary Massey, Massey and Company CPA serves the needs of small businesses and business owners from their office in Atlanta, GA.  They handle tax matters, IRS controversy, tax debts, back taxes, bookkeeping and accounting.  Offices are in the Buckhead neighborhood of Atlanta.   The firm welcomes face-to-face visits.

Gary Massey, CPA

Massey and Company CPA

P.O. Box 421396, Atlanta, GA  30342

Massey and Company 



If you are a business owner, you know how important it is to track your expenses. You are probably also aware that keeping track of your money is becoming more and more difficult in our fast-paced digital world. The online receipt capture feature by QuickBooks Online makes this as easy as possible.

When it comes time to filing taxes, you need to be prepared with an organized expense record for your business. This has been a difficult task in the past. However, with QuickBooks’ new online receipt capture feature, this task has changed. Now, keeping a current record of your expenses has never been easier!

“Audit-Proof” Your Business with the Snap of a Picture
QuickBooks Online has always given you the option to sync your bookkeeping records to your bank accounts, credit card accounts, Paypal and Square.  What’s new is that you can now take pictures of your receipts on your smart phone, using the QuickBooks app.  The pictures are attached to your transaction inside QuickBooks and saved forever.  No more paper.  And your books are now audit-proof, in case the IRS ever comes knocking.

And with the ease of the QuickBooks App, you can audit-proof your business from virtually anywhere! 

The Best Part – No Extra Fees!

The best part of this new feature is that it comes with no extra cost for users of QuickBooks Online.

This feature could change the way you run your business, and make your life easier.  Think about what it will be like to eliminate years of paper receipts with the click of a button!  Plus, imagine going to sleep at night without worries of the IRS challenging your expenses in an audit.

We can show you how Receipt Capture works.  Feel free to give us a call at 678-235-5460, or shoot Gary an email at  You can also contact us via our website.

Visit our firm’s YouTube Channel!

Founded by Gary Massey, Massey and Company is a boutique, Atlanta-based CPA  firm serving the needs of small businesses and their owners. We handle tax matters, IRS controversy, tax debts, back taxes, bookkeeping, and accounting. Our offices are in the Buckhead neighborhood of Atlanta and we welcome face-to-face visits
Gary Massey, CPA
Massey and Company CPA
P.O. Box 421396, Atlanta, GA  30342
Massey and Company