This article explains the procedures an organization must follow in appealing the imposition of Private Foundation Excise Taxes. Appeals of these taxes are handled by the local Appeals Office in each of the area offices of the Internal Revenue Service.
An excise tax appeals case may involve the following steps:
For appeal procedures that apply to cases involving issues subject to the declaratory judgment provisions of section 7428 of the Internal Revenue Code, see Declaratory judgment cases, and Chapter 1 of Publication 557, Tax-Exempt Status for Your Organization . These issues include qualification under section 501(c)(3) or as an operating foundation, classification as a private foundation, and eligibility to receive deductible charitable contributions.
Publication 892, Exempt Organization Appeal Procedures for Unagreed Issues