CHASE COUNSEL
PLLC

Legal Commentary

Drafting the IRS Appeals Protest: Developing the Facts, Preserving the Law, and Presenting the Hazards of Litigation

A practitioner-focused guide to preparing an effective administrative protest, developing the factual record, identifying disputed issues, presenting legal authorities, and positioning a federal tax controversy for resolution before the IRS Independent Office of Appeals.

By Chase Sizemore, JD, LLM

Law current through August 2026.

Chase Sizemore, Attorney

Attorney Chase Sizemore, JD, LLM

Principal, Chase Counsel PLLC

Georgetown Tax LLM | Former KPMG Auditor

U.S. Tax Court | Graduate Studies, Columbia University

National Institute for Trial Advocacy (NITA) Diploma

30+ Years of Legal Experience

Contents

This guide addresses IRS examinations and administrative appeals in federal tax controversies.

Federal Tax Controversy Representation

Chase Counsel represents taxpayers in selected federal tax controversies, including IRS examinations, administrative appeals, penalty disputes, collection matters, and proceedings before the United States Tax Court.

Schedule an Initial Case Screening

Call 703-403-1488