IRS Appeals
IRS Appeals is an independent office within the IRS where taxpayers can dispute IRS decisions before going to court. The process begins with a 30-day letter and allows taxpayers to protest assessed tax, penalties, interest, and collection actions through an informal conference.
Exam Tip
30-day letter = appeal to IRS Appeals. 90-day letter = notice of deficiency (Tax Court petition). Written protest required for amounts over $25,000. Appeals is independent from examination.
What is IRS Appeals?
The IRS Independent Office of Appeals resolves tax disputes without litigation. It is separate from the IRS examination function and provides an impartial review.
Appeals Process
| Step | Action |
|---|---|
| 1. 30-day letter | IRS proposes changes; taxpayer has 30 days to respond |
| 2. Protest filed | Written protest for amounts over $25,000; small case request for under $25,000 |
| 3. Conference | Informal meeting with Appeals Officer |
| 4. Resolution | Agreement, partial agreement, or no agreement |
| 5. 90-day letter | If no agreement, statutory notice of deficiency issued |
What Can Be Appealed
| Appealable | Examples |
|---|---|
| Examination results | Proposed tax adjustments |
| Penalties | Late filing, accuracy-related |
| Collection actions | Levies, liens, seizures |
| Offer in compromise rejections | OIC denials |
| Innocent spouse denials | Form 8857 denials |
Exam Alert
30-day letter = opportunity to appeal BEFORE court. 90-day letter = statutory notice of deficiency (last chance before Tax Court). Appeals conferences are informal. Taxpayer can bring representative (EA, CPA, attorney). Collection Due Process (CDP) hearing provides right to appeal collection actions.
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Related Terms
Enrolled Agent (EA)
An Enrolled Agent is a federally authorized tax practitioner who has earned the privilege of representing taxpayers before the IRS by passing the Special Enrollment Examination (SEE) or through IRS experience.
Installment Agreement
An installment agreement is an IRS payment plan that allows taxpayers to pay their tax debt over time in monthly installments, with several types available depending on the amount owed.
Innocent Spouse Relief
Innocent spouse relief provides relief from joint and several tax liability when a spouse or ex-spouse improperly reported items on a joint return. Three types exist: innocent spouse relief (Section 6015(b)), separation of liability (Section 6015(c)), and equitable relief (Section 6015(f)).
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