Every year, the Office of Appeals helps more than 100,000 taxpayers resolve their tax disputes without going to Tax Court. Appeals is an independent organization within the IRS whose mission is to help taxpayers and the government resolve tax disagreements. Appeals does not seek to take sides in a dispute; rather it offers an objective point of view on each individual case. It reviews each case after the applicable IRS compliance has made its decision and work to resolve disagreements in the case on a basis that is fair and impartial to both the government and the taxpayer.
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If you have a tax problem and disagree with the IRS decision, you can generally appeal in two ways:
- Internal: IRS Office of Appeals
- External: litigation in the federal court system
Most disputes with the IRS provide you the opportunity for an internal IRS appeal, and most disputes are settled there.
What types of IRS decisions can you appeal?
Here are a few common examples:
- The results of an audit or CP2000 underreporter notice
- Collection actions such as a levy, federal tax lien, or the IRS denial of your request for an installment agreement or offer in compromise
- IRS denial of your penalty relief request
Appeals can generally look at the facts, circumstances, IRS procedures, tax law, and other factors in making a final decision for the IRS. The IRS Office of Appeals operates independently from the IRS to reach an agreement between you and the IRS without having to go to court.
Appeals officers (or settlement officers) are generally the most experienced IRS employees. They specialize in the area of tax law or administration involved in the dispute. For example, if you’re contesting audit findings on a corporation, the appeals officer will have a good understanding of corporate tax law.
Remember: IRS decisions aren’t always final. You may have the right to appeal that decision – informally with an IRS manager and formally with IRS appeals.
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