Appeals

IRS Appeals: A Second Look at the Decision

The IRS Independent Office of Appeals is separate from the people who said no.

The examiner disagreed with you. The collection employee rejected your proposal. That is not always the end. The IRS Independent Office of Appeals is a separate office that reviews disputes, and most taxpayers never use it.

Collection Due Process

When the IRS files a notice of federal tax lien or proposes a levy, the Code gives you a right to request a Collection Due Process hearing within a 30-day window described in IRC 6320 and IRC 6330. That hearing is a chance to raise collection alternatives and challenge the action.

Write it like it matters

An appeal is an argument. Facts, law, and a clear request. Not a complaint letter.

Watch the deadlines

Every appeal right has a deadline, and missing it can cost you the right entirely. If you received a bad result, act quickly. If a fraud penalty is involved, read the civil fraud penalty guide first.

General information only, not legal advice. Reading this page does not create an attorney-client relationship. Laws and IRS procedures change; the sources cited were reviewed on the date shown above.

Before you talk to an agent

Exposure is a legal problem. Treat it like one.

If you think a tax problem could carry criminal exposure, talk to a lawyer before you talk to the IRS. Conversations with your lawyer are privileged. Conversations with an agent are evidence.