Most people assume that when the IRS says “no,” that’s the end of the story. Case closed. Move on.
But every once in a while, someone pushes back—and proves that the outcome isn’t always as final as it seems. A recent case out of Ohio is a perfect example.
A Denied Claim… and a Decision to Fight
In Greenwald v. United States, a single mother filed her tax return claiming refundable credits worth just under $8,000. The IRS denied them, citing a lack of documentation.
That’s typically where most taxpayers stop. She didn’t.
Persistence Changes the Game
Instead of accepting the denial, she:
- Filed a refund claim
- Went through the IRS appeals process
- Took the case all the way to federal court
On the surface, this might seem like a long shot—especially given the relatively small dollar amount involved. But there was one critical move that changed everything.
The Strategy That Made the Difference
Her attorney submitted what’s called a qualified offer—a formal, written proposal to settle the case for a specific amount. It’s a technical tool that is often overlooked and rarely used.
And in this case, the IRS didn’t respond. Their silence proved to be a costly mistake.
An Unexpected Outcome
After the case progressed through depositions and legal proceedings, the IRS made a surprising decision: They conceded. No trial. No final showdown. They simply agreed to pay the amount the taxpayer had been seeking.
At that point, it looked like a straightforward win. But wait – there’s more!
The Real Victory
Because the IRS failed to respond to the qualified offer, the rules shifted. The taxpayer wasn’t just entitled to the refund—she was also eligible to recover her attorney fees.
And that’s where things took a dramatic turn. Her original tax dispute was for $7,970. But she was awarded her attorney fees also which totaled over $34,000
Yes—the legal fees ended up far exceeding the amount of the original claim and she was able to get it all back!
What This Really Proves
This case isn’t just about beating the IRS—it’s about understanding how the tax system actually works.
Tax law isn’t limited to what you report on a return. It also includes a complex set of rules that govern how disputes are handled, when the IRS must respond, and what rights taxpayers have along the way. In this situation, the outcome turned not on new evidence, but on knowing how to properly navigate those rules—and when to use them.
That’s where most taxpayers are at a disadvantage.
Because while the IRS deals with these procedures every day, the average person may encounter them once in a lifetime—if at all.
This is exactly why having an experienced tax professional matters. Not just to prepare a return—but to understand the full landscape: the rules, the timing, and the strategies that can turn a “no” into something very different.
Why Most People Never See This Side
Situations like this are rare—not because they’re impossible, but because:
- Most taxpayers don’t know their options
- Many give up early in the process
- Few understand the strategic tools available
And to be fair, not every case will end this way. But this one clearly shows that persistence—paired with the right understanding—can shift the outcome in a meaningful way.
Final Thought
It’s easy to assume that once the IRS makes a determination, your only option is to accept it. But sometimes, it’s wise to question the first answer you receive.
Because in the right circumstances, even a denied claim can turn into a significant win.
If you need help resolving a tax problem, contact Saunders Tax & Accounting at http://www.saunderstax.com or call us at 301-714-2071. Open Monday – Thursday, 9 am to 5 pm. Awarded the Hagerstown Hot List 2026 and Hagerstown Chamber of Commerce “2023 Small Business of the Year” by providing a Less Taxing Life and More Prosperous Solutions since 1984!
