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IRS Appeals Procedure

Posted by Pietro E. Canestrelli | Oct 14, 2020 | 0 Comments

The IRS has finished its audit and has issued a “30-day letter” with proposed adjustments. What now? The IRS provides a forum for appealing a proposed income tax deficiency known as IRS Appeals. The Appeals Office is separate from – and independent of – the IRS office that issued the 30-day letter. The Appeals Office is the only level of administrative appeal within the IRS.

When you request an Appeals conference, you will also need to file a formal written protest with the office named in the 30-day letter. The protest must be filed before the end of the 30 days. However, the IRS may be willing to extend that deadline.

The Appeals Officer that is assigned to your case will set up a conference to discuss the case for possible settlement. The conference is informal and can be either in person or by telephone. The Appeals Officer must evaluate the hazards of litigation in every issue and is authorized to settle a case.

If there is no agreement on some or all of the issues after your Appeals conference, you may take your case to the United States Tax Court, the United States Court of Federal Claims, or the United States District Court, after satisfying certain procedural and jurisdictional requirements.

The Internal Revenue Service Appeals process can be a great way to settle a dispute with the IRS and is usually faster and less expensive than Tax Court. However, it is important that a taxpayer retain a qualified tax lawyer or representative if the issues involved are complicated or if the taxpayer thinks that they cannot handle the case themselves.


The information provided on this blog does not, and is not intended to, constitute legal advice; instead, all information, content, and materials available in this blog are for general informational purposes only. Information on this blog may not constitute the most up-to-date legal or other information. This blog contains links to other third-party websites. Such links are only for the convenience of the reader, user or browser; the Law Office of Pietro Canestrelli, a Tax Controversy Boutique, APC, and its members do not recommend or endorse the contents of the third-party sites.

About the Author

Pietro E. Canestrelli

J.D. LL.M Taxation Certified Bar Tax Specialist Founder & CEO


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