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 explaining the proposed adjustments and
informing 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, you will want to be prepared to
support your position.
In addition to examinations, many other things are appealable. 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 your 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, order
Publication 5, Appeal Rights and Preparation of Protest for Unagreed
Cases. Also, Publication 1660, Collection Appeal Rights (for Liens,
Levies and Seizures) discusses how you can appeal those actions.
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