Private Foundation Excise Tax Appeal Procedures: Thirty-Day Letter


When an examination results in a proposed tax deficiency or a change in exempt status, the taxpayer will be issued a 30-day letter including a report of the examination that indicates the proposed deficiency (or change in exempt status) and the reasons for it. The letter will also advise the taxpayer of the right to appeal the proposed action if the taxpayer does not agree with it.

The taxpayer may, within 30 days of the date of the letter, ask the Independent Office of Appeals (Appeals) to consider the case.  Procedures for Appeals consideration and claims for refund or credit are discussed in Protest and Conference Procedures  and Claims for Refund or Credit.  In situations where the expiration of the statute of limitations for assessment and collection of tax is imminent, extensions of time to file a 30-day protest will be granted only if the taxpayer signs a consent to extend the statute of limitations.

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