How to Win Against the IRS (Even if You Are Wrong)

Why It Matters

Understanding the IRS dispute process empowers taxpayers to avoid costly penalties and to negotiate better outcomes, directly impacting cash flow and compliance risk for businesses and individuals alike.

Key Takeaways

• IRS auditors are fact‑checkers, not judges of tax law.
• Appeals officers consider litigation risk, unlike auditors do.
• Build a clean factual record before contesting adjustments.
• Highlight hazards of litigation to encourage IRS settlement.
• Even strong IRS positions can lose without proper legal arguments.

Summary

The video demystifies tax disputes, showing taxpayers how to navigate an IRS audit, the subsequent appeals process, and, if necessary, tax‑court litigation. Jasmine Bilazarian, a tax attorney, CPA and enrolled agent, explains that the IRS is not a final authority and that understanding the procedural hierarchy is essential to achieving a favorable result.

She stresses that auditors act as fact‑checkers, demanding documentation and disallowing deductions lacking receipts. Their role ends once the audit closes, after which the case moves to the Office of Appeals, where officers can weigh the “hazards of litigation” and settle based on the risk of losing in court. The key to success is assembling a complete, organized record and framing arguments that create that litigation risk.

Bilazarian illustrates the point with the 2021 tax‑court case Anikeev v. Commissioner. Although the IRS had a seemingly strong legal position on credit‑card cashback rewards, the agency’s attorney failed to present an alternative basis‑adjustment argument, and the court ruled in the taxpayer’s favor. The decision now serves as a citation for similar disputes, underscoring how procedural missteps can overturn substantive merits.

For businesses and high‑net‑worth individuals, the takeaway is clear: the IRS can be challenged effectively if taxpayers understand where disputes are decided, prepare thorough documentation, and leverage the appeals‑stage focus on litigation risk. Proper strategy can turn a seemingly unwinnable audit into a negotiated settlement or even a court victory.

Original Description

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ABOUT JASMINE DILUCCI, JD, CPA, EA

Jasmine DiLucci has specialized in tax since high school when she first became licensed to represent taxpayers before the IRS.

Now as a tax attorney and CPA, she works with individuals and business owners across the nation to on Tax Planning, CFO Advisory, and IRS Tax Resolution

How Jasmine Got Here…

18: Became an Enrolled Agent, licensed to represent taxpayers before the IRS.

22: Earned an Accounting Degree and a Master’s in Finance.

23: Became a CPA

24: Stepped into leadership as she took over her own CPA firm

26-28: Juggled full-time studies at SMU Law while she was growing her CPA firm.

28: Graduated from law school 4th in her class and became an Attorney, all while managing her CPA firm.

29-31: Expanded her CPA firm to seven figures, with a focus on delivering top-notch service and exceptional value to every client.

32: Launched Tax Leverage to offer free online education and combat the rise of “tax gurus,” aiming to provide real, accessible tax knowledge.

Today: She’s dedicated to running her firm and leveraging her expertise to educate and empower others, helping individuals and businesses navigate the complexities of taxes and finance.

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Disclaimer: This information on this channel is for educational purposes only and does not constitute professional legal or tax advice.

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