The IRS has an appeals system for people who do not agree with the results of an
examination of their tax returns or with other adjustments to their tax liability.
If your examination or other adjustment was conducted through a personal interview
with an IRS employee, the employee will explain your appeal rights to you.
If you disagree with the findings, you may request a meeting with the employee's
supervisor. If you still do not reach an agreement, or if the examination or other
adjustment was conducted through correspondence, the IRS will provide you with a
report and/or letter that explains the proposed adjustments and informs you of your
right to request a conference with an appeals officer. The letter will also tell
you how to make your request. If you request an appeals conference, be prepared to
support your position.
In addition to examinations, many other things can be appealed. Among them are
penalties, including the trust fund recovery penalty, offers in compromise, employment
tax adjustments, liens, levies, seizures, abatement of interest, and other claims.
Appeals conferences are informal meetings. You may represent yourself at an appeals
conference; or, if you want, you may have an attorney, a certified public accountant,
or an individual enrolled to practice before the IRS represent you. If you do not
reach an agreement with the appeals officer, or you do not wish to appeal within the IRS,
you may take your appeal into the courts.
For further information on the appeals process and information on how to stop
interest from accruing on any anticipated liability, download
Appeal Rights and Preparation of Protest for Unagreed Cases, and
download Examination of Returns, Appeal Rights and Claims for Refund. Also, Publication 1660,
Collection Appeal Rights (for Liens, Levies and Seizures),
discusses how you can appeal those actions. These publications may also be
ordered by calling 1-800-829-3676.
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