IRS Appeals

What Are IRS Appeals?

IRS appeals give taxpayers a way to challenge an unfavorable IRS decision without going straight to court. The IRS Independent Office of Appeals is separate from the examination or collection function that issued the original determination, and its mission is to resolve disputes fairly for both the taxpayer and the government.

When to File an Appeal

Common situations that qualify include disputed audit adjustments, proposed penalties, rejected offers in compromise, and certain collection actions such as liens or levies. Timing is critical — most appeal rights come with strict deadlines that, once missed, may limit your options to formal litigation instead of a faster administrative resolution.

What to Expect in the Process

An appeal typically starts with a written protest laying out your position and the facts supporting it. An appeals officer independent of the original case then reviews everything, often resulting in a negotiated resolution rather than a full hearing. Related matters like U.S. Tax Court and IRS tax appeals or FBAR appeals can follow a similar path when foreign account issues are involved.

Preparing a Strong Protest

The strength of your written protest often determines how the case unfolds. A well-documented factual record, combined with a clear legal argument, gives the appeals officer what they need to resolve the matter favorably without escalating further. Cases tied to FBAR penalties or unresolved foreign information returns often benefit from this same approach.

How We Help

Our CT tax attorneys and CPAs prepare and present appeals with the documentation and legal argument needed to get a fair result. Contact us today to discuss your situation before your deadline passes.