Appeal rights are explained by the examiner (auditor) at the beginning of each audit. Taxpayers who do not agree with the proposed changes may appeal by having a supervisory conference with the examiner’s manager or appeal their case administratively within the IRS, to the U.S. Tax Court, U.S. Claims Court or the local U.S. District Court. If there is no agreement at the closing conference with the examiner or the examiner’s manager, the taxpayer has 30 days to consider the proposed adjustments and their next course of action.
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If you and the IRS auditor do not agree on the proposed changes to your tax return, you can request a conference with the auditor’s manager. Requesting a manager conference may solve the dispute before going to appeals, however requesting the manager conference does not extend the 30-day appeals period you have once the audit report is sent to you.
The appeals process can be lengthy so requesting a manager conference may bring a faster resolution to your audit. If you disagree with the manager’s decision, you can still file an appeal with the IRS Office of Appeals within the 30-day period from the date on your audit report.