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 liabilities.
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, 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 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 and Publication 556,
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. Publications and forms may
be downloaded from this site
or ordered by calling 1-800-829-3676.
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