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If you disagree with the findings of an IRS audit, you have the right to appeal the decision. The IRS Audit Appeals Process provides taxpayers with a fair and independent way to resolve disputes without going to court.
At Z Tax & Accounting, our IRS Enrolled Agents help individuals and businesses navigate the appeals process, protect their rights, and achieve the best possible resolution.
The IRS Office of Appeals is an independent division within the IRS tasked with resolving disputes between taxpayers and the IRS. The process ensures that taxpayers have a neutral forum to present their case and seek a fair outcome.
The appeals process applies to:
Collection disputes
Penalties and interest assessments
1. Receiving a 30-Day Letter
After an audit, the IRS may issue a 30-day letter (Letter 525), detailing proposed changes.
You have 30 days to respond, either by agreeing, paying, or formally appealing the audit findings.
2. Filing a Written Protest
For disputes over $25,000 or more, a formal written protest is required.
For amounts under $25,000, a small case request may suffice, using IRS Form 12203.
Your protest should include:
Taxpayer information
Tax periods in question
Explanation of disagreements
Supporting facts and documentation
3. Appeals Conference
Once the written protest is received, the IRS schedules a conference with an Appeals Officer.
This officer is independent of the audit team and will review the case objectively.
Conferences can be conducted in person, by phone, or via correspondence.
4. Negotiation and Resolution
Appeals Officers review evidence, apply tax law, and negotiate settlements.
Options may include partial adjustments, penalty reductions, or full agreement.
Most cases are resolved without litigation, saving time and expense.
5. Receiving an Appeals Decision
After review, the Appeals Office issues a written determination.
You can either accept the decision or proceed to Tax Court or other judicial options if unsatisfied.
Independent review by a neutral officer
Potential reduction of penalties and interest
Avoiding lengthy litigation and court fees
Preservation of taxpayer rights under the Taxpayer Bill of Rights
Form 12203 — Request for Appeals Review (Small Case)
Formal Written Protest (for disputes over $25,000)
Supporting documentation and schedules relevant to your audit
Power of Attorney (Form 2848) if represented by a tax professional
Navigating an IRS audit appeal can be complex. Our team provides:
Preparation and submission of written protests
Representation in Appeals conferences
Negotiation of settlements to minimize tax, penalties, and interest
Advice on judicial options if Appeals resolution is not favorable
📞 Contact Z Tax & Accounting today to protect your rights and ensure a successful IRS audit appeals process.