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The IRS has an administrative appeals process that works with taxpayers to try to settle tax disputes in an effort to avoid formal court hearings. The role of Appeals is to make an independent review of a tax dispute and to consider the positions taken by both the taxpayer and the IRS. The Appeals unit 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 letter 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, offers in compromise, liens, and levies. If you request an Appeals conference, be prepared with records and documentation to support your position.
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 do not reach agreement with the Appeals or Settlement Officer, or you do not wish to appeal within the IRS, you may appeal certain actions through the courts.
For further information on the appeals process 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 660 (PDF), Collection Appeal Rights. Learn more about Appealson IRS.gov where you will find information about alternative dispute resolution processes, technical guidance, international programs, and more.