IRS Examination and Appeals
The IRS Independent Office of Appeals sits apart from the examiners and collection officers whose decisions it reviews. Its job is to settle cases without litigation, and it can weigh the risk of the IRS losing in court in a way the original decision maker cannot.
Also called: IRS appeals, appealing an IRS decision, appeals conference, protest letter.
An examiner applies the rules to the facts in front of them. Appeals is allowed to consider what would happen if the matter were litigated, which gives it room to settle on grounds that were unavailable earlier. A case that looked immovable at examination can move at Appeals for that reason alone.
The forum is real and it is used constantly. Most disputes that reach Appeals resolve there rather than in court.
Access is through a written protest filed within the window given in the letter you received, and the requirements for that document depend on the amount in dispute. The protest frames the case, and a poorly framed one narrows what can be argued later.
Appeals also handles collection disputes, not just examination results. Collection due process hearings and the collection appeals program both run through it and both carry their own short deadlines.
Certified Taxpayer Representative™ holders are listed first, then by membership level. Every listing is a licensed professional reviewed by hand before it appears.
There is no filing fee for an administrative appeal. Interest continues to accrue on any unpaid balance while the dispute runs.
Months rather than weeks, and longer for complex cases. Collection is generally suspended for the types of appeal that carry that protection.
Depending on the type of case, the next step may be the Tax Court or another judicial route, each with its own strict deadline running from the decision.
Other work in irs examination and appeals.
This page is general information about how the IRS handles this kind of matter. It is not advice about your situation, and no outcome is being promised. Results depend on your own facts. Speak to a licensed professional before you act. The directory is a free member benefit of Tax Resolution Academy®, and there is no way to pay for a higher position in it.
