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One of the most overlooked options when challenging an IRS assessment is that the validity of these assessments can be challenged in the bankruptcy court. If the challenge is successful, the bankruptcy can be dismissed. Most bankruptcy court judges are generally more lenient towards the taxpayer than a United States Tax Court judge.
Another avenue to consider is to file an Offer in Compromise with the IRS. This can be filed even if the taxpayer did not appeal the original assessment. If the IRS rejects the offer, the taxpayer can appeal this decision internally within the IRS. This has a better chance than it may seem because IRS appeals officers are judged on their ability to resolve cases, not solely on their assessment/collection amounts.
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