FACTS: Bret and Samantha Woodley have been our clients for many years. We have recently concluded an IRS audit of their 2017 income tax returns and the result was an increase in taxable income of $43,750. In our opinion the IRS auditors have ignored the facts in this case and have incorrectly applied the internal revenue code in their conclusions.

ISSUE: Bret and Samantha Woodley are very upset and worried that they can not afford to pay the increased tax of $16,188. We have told them that this is only the first step. We can always go to appeals and then court if necessary. They have said that appeals is just another arm of the IRS and will just agree with the auditors findings and this amount is too small to incur the costs of litigation. What can we tell them so they are not so worried about fighting this assessment?

CONCLUSION?:

BASIS FOR CONCLUSION?: (Case or litigation from 2019 that backs up conclusion)