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.