Appeals Process

[Corduroy Frog]

I've just been through an audit with a client who already owes $16K, but the auditor is piling on another $25K in audit adjustments.
The auditor acted with unprovoked vengeance and I felt the $16K was bad enough, and disagree with ALL of the $25K in audit adjustments.

We have a limited time to appeal. What I am asking is a real-world opinion of what I am looking at with appealing this to another audit official. My experience is somewhat limited because I usually do much better in audits. The appeals officer, in my limited experience, tends to be more defensive of the first auditor than to be objective.

After an appeal, what is next in the appeals process and will a further appeal tend to be even more of a risk because of their defense of the audit process?

Once having my appeal appointment set, should we simply engage a tax attorney to get our best deal? I know a couple.

[Corduroy Frog]

Bumping Up

Thought I would bump this up, as I believe there are some of you who have been further up the ladder than I have
on the appeals process. The best of us are already very busy.

The IRS is ever-abundant with information about their appeals process and how fair it is. For some reason, I think real
world experience would be more helpful at this point.

My record in dealing with primary auditors has been pretty decent if the client is honest with me. This auditor seems to
have lost all reason.