Since administrative appeals usually require significantly less preparation than litigation, the costs may be significantly lower. This give and take atmosphere is generally absent in court proceedings. In addition, the time required to settle a dispute is usually much shorter than for litigation. Together these factors reduce the level of stress experienced by the taxpayer. An important advantage of a negotiated settlement is that the taxpayer has a much broader choice of representation.
Many tax advisors are CPAs.
In an administrative proceeding, the taxpayer can be represented by the original preparer. If the taxpayer is considering litigation and the original preparer is not an attorney, an additional issue arises since persons other than attorneys are rarely permitted to represent taxpayers in court. The additional time and expense required often constitutes a significant hurdle to litigation. Attorneys may represent taxpayers in any of the courts. Non-attorneys are unequivocally excluded from practicing in the claims and district courts.