If your case qualifies for an appeal, we’ll review the issues of your case with a fresh, objective perspective and schedule a conference with you. Our conferences are informal and are conducted by correspondence, telephone, video conference or in-person. We may be able to resolve your disputed issues and help you to avoid the time and expense of a court trial. We’ll consider any reason you have for disagreement, except for: Moral Religious Political or constitutional arguments Conscientious objections or similar grounds Our commitments – we will: Explain your appeal rights and the appeal process Listen to your concerns, be courteous and professional Be timely and responsive Be fair and impartial Your responsibilities – you should: Listen to our explanation of your appeal rights and the appeal process, including the timeframe to resolve your case. State the issues with which you disagree, explain why and provide your understanding of the facts and the law in your case. Provide us any additional information or documentation that may be helpful to your case within the timeframe specified by the appeals officer or settlement officer.Note: If you present new information that you didn't provide to the auditor or revenue officer, we may return your case or refer that information for further consideration. You'll receive the auditor's or revenue officer's comments and will have an opportunity to respond. Be timely and responsive to our requests for scheduling and information. General Information The organizational structurePDF of the IRS Independent Office of Appeals (Appeals) is designed to address the wide variety of cases and issues handled by the IRS. The time it takes to resolve your case in Appeals will vary, depending on the facts and circumstances of your case. After you’ve been contacted by Appeals, questions about specific timeframes should be directed to the appeals office or settlement officer assigned to your case. If you’ve encountered difficulties in dealing with the IRS or have concerns about your tax matters that the IRS hasn’t been able to resolve, you may wish to contact your Local Taxpayer Advocate office for assistance. Appeals may call you if you filed a petition with the U.S. Tax Court Appeals seeks to resolve disputes between taxpayers and the IRS without the need for litigation. Taxpayers who file a petition in the U.S. Tax Court and who haven’t had a prior opportunity to attempt to resolve their case with Appeals may be contacted by Appeals. Traditionally, Appeals contacts the taxpayer by mail offering to discuss possible settlement of the case. To improve the timeliness of the settlement process, Appeals has begun making initial contact with certain taxpayers (or the taxpayer’s authorized representative, if any) by telephonePDF. This telephone contact generally will occur in cases where the taxpayer petitioned the court as a result of a letter from the IRS correspondence examination unit or the income underreporter unit. Appeals recognizes that some taxpayers may be concerned that a caller claiming to be from IRS Appeals truly is from Appeals. How can you know if a call is really from IRS Independent Office of Appeals? Did you file a petition with the U.S. Tax Court? If the answer is yes, you may receive a call from an appeals officer to discuss your tax dispute and options for resolution. If an appeals officer cannot reach you by phone, they may leave a general voicemail message. When an Appeals employee leaves a voicemail, they will include self-identifying information such as their name, title, badge number, and contact information. Appeals call verification procedures During the call, the appeals officer will provide you with their name, their badge number and their contact information including their phone number, e-fax, and email address. The appeals officer will also know the docket number as well as specifics regarding your case. Appeals employees will never ask for your credit card or banking information. Also, during this call, Appeals employees may ask you to submit additional documentation regarding your petition directly to the Independent Office of Appeals via mail, fax, or to an email address ending with @irs.gov. Access to case file You may be entitled to a copy of the administrative case file sent to Appeals with your appeal request. If you meet the criteria, we’ll provide you with an opportunity to request that information prior to your Appeals conference. The process will be explained in more detail by the Appeals employee assigned to your case. Taxpayer Advocate Service If you’ve encountered difficulties in dealing with the IRS or have concerns about your tax matters that the IRS hasn’t been able to resolve after multiple attempts, you may wish to contact your Local Taxpayer Advocate office for assistance. Frequently Asked Questions I want to appeal the decision reached by the IRS Examination or Collection office. Should I contact Appeals directly? No. Appeals can’t assist with resolving your tax matters until your request for an appeal has been processed by the IRS office working your case. If you’ve considered an appeal and decided to request an appeal, you may do so by filing a written protest. Complete your protest and mail it to the IRS address on the letter that explains your appeal rights. Don’t send your protest directly to the Independent Office of Appeals; this will only delay the process and may prevent us from considering your case. I sent my appeal request to the IRS office that worked my case. What happens next? IRS Examination or Collection office that made a tax assessment or initiated collection action will consider your protest and attempt to resolve the disputed tax issues. If that office can’t resolve these issues, they will then forward your case to us for consideration. Don’t contact Appeals until after this happens. When should I expect to hear from Appeals? You can expect to hear from us after we receive and review your case. If you haven’t heard from us and it’s been more than 120 days since you filed your protest requesting an appeal, contact the IRS office to which you sent your appeal request. If you don’t know which IRS employee or office last worked your case, call the IRS taxpayer assistance line. The IRS office where I submitted my request for an appeal says they forwarded my case to Appeals. How can I find out who is handling my case? We can tell you if your case has been assigned to an Appeals employee and how to contact that employee directly. The assigned Appeals employee is your best contact for all issues related to your Appeals case. You can reach us at 855-865-3401. Leave a message with your name and identifying number and we’ll research the status of the case and return your call within 48 hours. If we haven’t received your case yet, you won’t receive a call back from us. I have questions or concerns that the Appeals employee assigned to my case is unable to address. Who can I contact for additional help? (updated July 25, 2023) You should begin by asking to speak with the Appeals employee’s manager. This contact information will be available on the letter you received acknowledging receipt of your case in Appeals. If they’re also unable to address your questions or concerns, you may ask to speak with the area director with authority over that office. How long will it take for Appeals to work my case? The time it takes for Appeals to work your case depends on several factors. These include, but are not limited to, the type of case, the facts of the case, the complexity of the issues, the availability of legal precedents, other legal theories involved and Appeals’ determination of the hazards of litigation. If you have petitioned the United States Tax Court prior to coming to Appeals, you have a “docketed” case and the time involved will also be affected by dates and timeframes established by the court and beyond Appeals’ ability to control. Cases received directly from Compliance that have not been petitioned to the Tax Court are referred to as “non-docketed” cases. For more information on average timeframes for non-docketed cases, please visit Independent Office of Appeals Customer Satisfaction Surveys. If I’m still unable to have my concerns addressed, is there a higher-level official I can contact? (updated July 25, 2023) Each of the Appeals’ functions has an executive overseeing their operations. If your concerns rise to that level, you may contact the appropriate executive office. For information on each function, refer to the Appeals’ organizational chartPDF. Who should I contact if I have a significant question or concern about the operation of the IRS Independent Office of Appeals? Significant questions or concerns about the operation of Appeals may be directed to the Appeals’ headquarters office. Letters may be addressed to: Internal Revenue Service Independent Office of Appeals 1111 Constitution Avenue NW - Room 3615 Washington, DC 20224 Do not mail your appeal request to this address. This office does not process appeal requests. Mail your appeal request directly to the IRS person or office that made the determination you seek to appeal. For additional information on the structure and leadership of the IRS Independent Office of Appeals, refer to the Appeals’ organization chartPDF.
