Topic Number: 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 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 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, interest, trust fund recovery penalties, liens, levies, and 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, accountant, or an individual enrolled to practice before the IRS represent you. 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.pdf, Your Appeal Rights and How to Prepare a Protest If You Don't Agree, and Publication 556, Examination of Returns, Appeal Rights and Claims for Refund. You can also refer to Publication 1660.pdf, Collection Appeal Rights. Visit Appeals to find information about alternative dispute resolution processes, technical guidance, international programs, and more.
You can also learn more about the Appeals process by reviewing the Appeals Process: Exam Issues YouTube video. Get the latest Appeals news, information, and settlement guidelines by following the IRS News and IRS Tax Professionals Twitter accounts as well.