Either CPA or a tax attorney may represent you in the Tax Court - and either may represent your appeal case.
I am not sure why the attorney cannot represent you in the court... If that is an issue and you are looking for representation - you might ask if your attorney may recommend someone else.
There are different appeal cases - some are resolved by the IRS Office of Appeals - some are resolved via mediation services through Fast Track Settlement and other programs managed by the IRS - and some are going going to the Tax Court.
You are not required - but may have representation on every step.
As your CPA recommended to appeal - he might had some reasons for that. The best would be to ask that CPA for some recommendations - he might recommend another CPA to takeover your case.
protection is definitely an option - but I would have it as the last resort.
But if you do - you need to be sure that you will be able to cover the tax debt.
If the income
tax debt meets all five of these rules
, then the tax debt is discharged in bankruptcy petitions.
The due date
for filing a tax return
is at least three years ago.
The tax return was filed at least two years ago.
The tax assessment
is at least 240 days old.
The tax return was not fraudulent.
The taxpayer is not guilty of tax evasion.
Sorry for your situation.
Unfortunately - it looks complicated and most likely you do need representation.