Tax Dictionary – IRS Appeals

IRS Definition:

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.

More from H&R Block:

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.

Get expert help handling your tax problem or appeal with the IRS.

Related Topics

Related Resources

Two Things You Must Know Before You Check the Box on Your CP2000 Notice

With CP2000 notices, make sure you preserve your rights when you respond to the IRS. Mainly, your right to protest penalties and your right to appeal.

How to Handle IRS Tax Return and Account Problems

Learn what to do if the IRS asks for more information to process your return, holds your refund, or sends a notice about changes to your return. Get the facts about IRS return and account problems.

Tax Dictionary – IRS Penalties

Get the facts from H&R Block about the most common IRS penalties for filing and paying late and learn how to request penalty removal if you qualify.

IRS Notice CP27 – Important Information About the Earned Income Credit

You may qualify for an additional tax credit. Learn more about notice CP27 and how to handle this notice with help from the tax experts at H&R Block.