No. 03Practice area I · Notices & Audits
IRS Appeals & Tax Dispute Representation

Disagree with the IRS? You have the right to be heard.

Many IRS decisions can be reviewed by the Independent Office of Appeals, separate from the office that made them. We build your case, meet the deadline, and represent you in the appeal.

Form 12203Collection appealsEnrolled Agent led
Two roads after a disagreement Illustration of an IRS decision that can lead to the Independent Office of Appeals, generally requested within 30 days of the letter, or to the U.S. Tax Court, petitioned within 90 days of a notice of deficiency. Illustration Two roads, two clocks IRS decision Office of Appeals Independent review Generally 30 days to ask U.S. Tax Court After a notice of deficiency 90 days, no extensions The exact deadline is printed on your letter

Illustration only. Some decisions have other appeal routes, each with its own deadline.

Who it is for

Is this you?

Disagreeing with the IRS is more common than people think, and the law gives you ways to be heard. Reach out if any of these sound familiar.

An audit ended badly

The examiner’s report adds tax or penalties you believe are wrong.

A letter with appeal rights

You received a letter explaining your right to appeal, and the clock is running.

A collection action you dispute

A lien, a levy, or a rejected payment plan does not fit your situation.

A notice of deficiency

You received a 90 day letter and need to know your options quickly.

What can be appealed

Many decisions, one independent review.

Appeals reviews a wide range of IRS decisions, from audit results to collection actions and penalties.

Independent Appeals Audit resultsPenaltiesLiensLeviesRejected offersPayment plan decisionsInnocent spouseTrust fund penalty
  • Audit results
  • Penalties
  • Liens
  • Levies
  • Rejected offers
  • Payment plan decisions
  • Innocent spouse
  • Trust fund penalty
Separate by design

Appeals works apart from the IRS office that made the decision, to keep its review impartial.

Outside the courtroom

Its purpose is to resolve tax disputes fairly without going to court.

Through the right door

Requests go to the address on the letter with your appeal rights, not directly to Appeals.

Each type of decision has its own appeal process and deadline, shown on the IRS letter.

Choosing the route

The right door, at the right time.

How you appeal depends on the decision and the amount. A strong request is clear about what you disagree with and why.

  • A list of the items you disagree with.
  • The reasons you disagree, supported by facts and documents.
  • The law or other authority that supports your position.
  • Sent within the time limit on the letter, generally 30 days.
Which route fitsFive doors
01
Small case requestAudit disagreements of $25,000 or less per period
Form 12203
02
Formal written protestAudit disagreements above $25,000, with facts and law
Written protest
03
Collection Due ProcessProposed levies and filed liens, by the date on the notice
Form 12153
04
Collection Appeals ProgramLiens, levies, and payment plan decisions. Quicker, but final
Form 9423
05
Tax Court petitionAfter a notice of deficiency. 90 days, which cannot be extended
Petition
The process

From disagreement to a fair review.

Five steps, with one point of contact the whole way through.

  1. 1

    Free case review

    We read the decision, the letter with your appeal rights, and the deadline.

  2. 2

    Power of attorney and file

    With Form 2848 on file, we gather the examiner’s report, your transcripts, and the case history.

  3. 3

    Build the protest

    We organize the facts, the documents, and the law into a clear written request.

  4. 4

    File on time

    We send the request to the address on your letter before the deadline.

  5. 5

    Represent you

    We present your case in the Appeals conference and keep you informed at every step.

Good to know

What to know about appeals.

A few facts that protect your options.

Appeals is independent

It works separately from the IRS office that made the decision, to keep its review impartial.

The deadline is on the letter

Most requests are due within the time limit shown on the letter, generally 30 days.

The Tax Court clock does not pause

After a notice of deficiency, talking with the IRS does not extend the 90 days to petition the Tax Court.

Our role

What we do for you.

An Enrolled Agent leads your case, with the same person handling it from the first call to the final result.

Deadline first

The first thing we confirm is the date that protects your rights.

A protest built on facts and law

We write the request the way Appeals reviews it: issue by issue, with support for each one.

Represented at Appeals

We handle the conference and the conversations, so you do not face the IRS alone.

Collection appeals too

Liens, levies, and payment plan decisions have their own routes, and we use the one that fits.

Questions

About IRS appeals.

The questions we hear most. Anything else, ask us during your free case review.

Is Appeals part of the IRS?

Yes, but it is independent from the office that made the decision. Its role is to review disputes fairly and impartially, outside of court.

Do I have to go to court?

No. Most disputes can be resolved through Appeals. The Tax Court is a separate option with its own deadline, usually after a notice of deficiency.

I received a notice of deficiency. What now?

You generally have 90 days to petition the Tax Court, or 150 days if the notice is addressed to you outside the U.S. The IRS cannot extend it, so contact us right away.

Can I appeal a lien, a levy, or a rejected payment plan?

Often, yes. Collection Due Process and the Collection Appeals Program cover these decisions, each with its own form and deadline.

Disagree with the IRS? Let us make your case.

Send us the letter with your appeal rights. The first case review is free and confidential.

Free case reviewNo obligationOne point of contact