IRS Appeals: A Second Chance to Win
The IRS examiner ruled against you. The collection officer denied your request. That's not the end. The IRS Office of Appeals exists specifically to give taxpayers a fresh look at their case. Most people don't use it. That's a mistake.
What IRS Appeals Does
Appeals is independent from the IRS division that made the original decision. The Appeals officer can settle cases based on the 'hazards of litigation' — meaning what would happen if the case went to court. They have authority to compromise that front-line employees don't.
Collection Due Process
If the IRS filed a lien or intends to levy, you have the right to a Collection Due Process hearing. This is an appeal with teeth. During the hearing, the IRS cannot take collection action. I use CDP hearings to negotiate better outcomes.
The Protest Letter
To get to Appeals, you need a written protest explaining why the IRS decision is wrong. This isn't a complaint letter. It's a legal argument citing facts, law, and authority. I write protests that get results.
Timing
You typically have 30 days from an adverse decision to request Appeals. Miss that window and your options narrow significantly. Don't sit on a notice.