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IRS.gov Website
Rev. date: 1/1/2011


Your Appeal Rights

Tax Topic 151
rule
The IRS has an appeals system for people who do not agree with the results of an examination of their tax returns or with other adjustments to their tax liability.
The IRS will send you a report and/or letter that explains the proposed adjustments. The letter also tells you of your right to request a conference with an Appeals officer, as well as how to make your request for a conference. In addition to examinations, many other things can be appealed such as penalties, interest, trust fund recovery penalties, offers in compromise, liens, and levies. If you request an Appeals conference, be prepared with records and documentation to support your position.
Appeals conferences are informal meetings. You may represent yourself or have an attorney, certified public accountant, or an individual enrolled to practice before the IRS, represent you. If you do not reach agreement with the Appeals or Settlement Officer, or you do not wish to appeal within the IRS, you may appeal certain actions through the courts.
For further information on the appeals process and information on how to stop interest from accruing on any anticipated liability, refer to Publication 5, Your Appeal Rights and How To Prepare A Protest If You Don't Agree, and Publication 556, Examination of Returns, Appeal Rights and Claims for Refund. You can also refer to Publication 1660, Collection Appeal Rights, which discusses how you can appeal collection actions, and Publication 3605, Fast Track Mediation–A Process for Prompt Resolution of Tax Issues.