How a Lawyer and Former IRS Agent Can Help You Win an Appeal or IRS Judgment

Facing an IRS judgment or preparing to appeal a tax decision can be overwhelming. The stakes are high, and the procedures are complex. Fortunately, working with a tax attorney who is also a former IRS agent can give you a unique advantage. At The Law Office of Pietro Canestrelli, A.P.C., we offer precisely that combination of legal acumen and insider IRS knowledge to help clients throughout Temecula, San Diego, Riverside, San Bernardino, and all of Southern California.

Why You Need Professional Representation in IRS Appeals

The IRS Appeals Office is the agency’s independent division that resolves tax disputes without litigation. However, navigating this process is far from simple. A minor procedural error or an incomplete submission can lead to a denial or delay in your appeal.

Key Challenges in IRS Appeals:

• Strict deadlines and documentation requirements
• Complex tax codes and regulations
• Limited opportunity to present new evidence
• Pressure to settle quickly

An experienced tax attorney ensures that your appeal is both timely and strategically structured. Even more powerfully, when your representative is a former IRS agent, they bring firsthand knowledge of how the system works from the inside.

Advantages of Hiring a Former IRS Agent

Former IRS agents understand how the agency evaluates cases. This background enables them to anticipate challenges and develop strong counterarguments.

Benefits include:

• Insider insight: They know how IRS personnel think and what documentation is most persuasive.
• Procedural fluency: They are well-versed in audit techniques and appeal processes.
• Negotiation leverage: Their credentials alone can shift how your case is treated.

At our firm, tax attorney Pietro Canestrelli combines legal skill with experience from inside the IRS, giving clients an edge in high-stakes tax controversies.

Common Scenarios Where Appeals and Representation Matter

You might need to appeal an IRS decision or respond to a tax judgment in many scenarios, including:

• Audit Reconsideration: If you’ve received an unfavorable audit result, IRS audit representation is critical.
• Tax Court Appeals: Legal expertise is essential if your case advances beyond administrative remedies.
• IRS Notices and Adjustments: Responding effectively to a CP2000 or similar notice requires detailed knowledge of tax law. Visit our IRS Notice page for more.
• Offer in Compromise Rejection: We help you strengthen your case and refile appropriately. Learn more about offers in compromise.

Our Strategic Approach to IRS Appeals

We offer a thorough, strategic process tailored to each client’s case:

1. Case Review and Assessment

We begin by analyzing the IRS records and your financial situation to identify any errors or weaknesses in the original determination. We also evaluate the legal standards applied and whether the IRS exceeded its authority or failed to consider mitigating circumstances.

2. Document Preparation and Filing

Our team ensures all filings are complete, accurate, and persuasive—maximizing your chance of success. This includes drafting Form 12203 (Request for Appeals Review), supporting memos, and assembling any omitted or updated documentation to reinforce your position.

3. Representation and Negotiation

We present your case to the IRS and negotiate on your behalf, using every tool at our disposal to argue for your best outcome. Whether through written briefs, phone conferences, or in-person appeals conferences, our advocacy is tailored, evidence-backed, and strategically framed.

4. Ongoing Communication

We keep you informed throughout the process and prepare you for any in-person meetings or calls with IRS personnel. Communication includes progress updates, expectations management, and preparation for any rebuttals or clarifications requested by the IRS Appeals Officer.

Regional Expertise That Matters

Our familiarity with local IRS offices and appeals units across Southern California sets us apart. We’ve worked extensively with IRS facilities and personnel in:

• Temecula and Riverside County – where many small business owners and individuals face audits or judgments related to self-employment income and local real estate investments.
• San Diego – involving complex appeals stemming from cross-border taxation, military benefits, and startup-related deductions.
• San Bernardino and Inland Empire – where economic pressures have led to increased IRS scrutiny and penalties.

Why Choose The Law Office of Pietro Canestrelli, A.P.C.?

• A tax attorney with former IRS experience
• Personalized, one-on-one service
• Representation throughout Temecula, San Diego, Riverside, and beyond
• Transparent communication and clear guidance
• Deep understanding of California-specific tax dynamics

We’ve helped numerous clients reduce penalties, win appeals, and resolve overwhelming tax debts.

FAQs: IRS Appeals and Judgments

How long do I have to file an IRS appeal?

Generally, you have 30 days from the date of your IRS notice to request an appeal. This can vary depending on the type of notice.

Can I represent myself in an IRS appeal?

Yes, but it’s risky. IRS procedures are complex, and even small mistakes can hurt your case. Legal representation significantly improves your chances.

Will hiring a former IRS agent really help?

Absolutely. Former agents understand the IRS from the inside out and can craft the most effective appeal strategy.

Do you only serve clients in Temecula?

No. We represent clients across California and throughout the United States.

Take the First Step Toward Resolution

If you’re facing an IRS judgment or need to file an appeal, don’t navigate the process alone. Let The Law Office of Pietro Canestrelli, A.P.C. help you fight back with experience, insight, and results.

Contact us today for a confidential consultation.