What to Expect from Appeals

If your case qualifies for an appeal, we will review the issues of your case with a fresh, objective perspective and schedule a conference with you. Our conferences are informal and conducted by correspondence, by telephone or at a personal conference, either in person or virtually. We may be able to resolve your case, helping you to avoid the time and expense of a court trial. We will 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 Appeals 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 Appeals process, including the timeframe to resolve your case
  • State the issues with which you disagree and why and explain your understanding of the facts and the law in your case
  • Give us any additional information or documentation that will be helpful to your case within the timeframe specified.
    Note: If you present new information that you did not provide to the auditor or revenue officer, we may return your case or refer that information for further consideration. You will 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 structure PDF of the IRS Independent Office of 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 circumstance specific to 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.

Frequently Asked Questions

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.

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.

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.

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 559-233-1267. 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.

You should begin by asking to speak with the Appeals employee’s manager. If they are also unable to address your questions or concerns, you may ask to speak with the Area Director with authority over that office.

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.   

 

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 and a functional contact point, refer to the Appeals’ organizational chart PDF.

Significant questions or concerns about the operation of Appeals may be directed to the Appeals’ Headquarters office by calling 202-317-8975. Letters may be addressed to the Headquarters’ office at:

Internal Revenue Service
Appeals HQ NC Room 717
1111 Constitution Ave NW
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 chart PDF.