Topic no. 151, Your appeal rights

The IRS works with taxpayers to try to settle tax disputes in an effort to avoid court proceedings through an administrative appeals process. The role of the IRS Independent Office of Appeals (Appeals) is to make an independent review of a tax dispute and to consider the positions taken by both the taxpayer and the IRS. Appeals strives to resolve tax disputes in a fair way and remain impartial to both parties.

The IRS will send you a report and/or letter that will explain the proposed adjustments or proposed or taken collection action. The correspondence also tells you of your right generally to request a conference with an Appeals or Settlement Officer, as well as how to make your request for a conference. In addition to examination adjustments, many other things can be appealed, such as penalties, denial of interest abatement, trust fund recovery penalties, liens, levies, and rejection of offers in compromise. If you request an Appeals conference, be prepared to support your position with records and documentation.

Appeals conferences are informal meetings. You may represent yourself, or have an attorney, certified public accountant, or other individual authorized to practice before Appeals represent you. For more information, see Circular No. 230, Regulations Governing Practice Before the Internal Revenue ServicePDF. If you don't reach an agreement with the Appeals or Settlement Officer or you don't wish to appeal within the IRS, you may appeal certain actions through the courts.

For further information on Appeals and information on how to stop interest from accruing on any anticipated liability, refer to Publication 5, Your Appeal Rights and How to Prepare a Protest If You Don't AgreePDF and Publication 556, Examination of Returns, Appeal Rights and Claims for Refund. You can also refer to Publication 1660, Collection Appeal RightsPDF and Publication 1, Your Rights as a Taxpayer. Visit Appeals to find information about alternative dispute resolution processes, technical guidance, international programs, and more.

Get the latest Appeals news, information, and settlement guidelines by following the IRS News and IRS Tax Professionals accounts as well.