Tax Tip 2023-79: Taxpayers can appeal when they disagree with an IRS decision

IRS Tax Tips

June 12, 2023

Issue Number: Tax Tip 2023-79

Taxpayers can appeal when they disagree with an IRS decision

When taxpayers disagree with the IRS?s decision on their tax situation, they can submit a written request to have the IRS Independent Office of Appeals review the decision. The goal of Appeals is to resolve tax disputes outside of the courtroom in a way that is fair and impartial and encourages voluntary compliance with tax law. This office is separate from the rest of the IRS in order to ensure its impartiality.

Who can file an appeal
A taxpayer may be eligible to file an appeal if they:

Received a letter from the IRS explaining their right to appeal the IRS?s decision
Disagree with the IRS?s decision
Haven?t signed an IRS agreement form sent to them

Taxpayers should review the facts and tax law relevant to their situation and gather any documents needed to support their position.

Requesting an appeal
If taxpayers are eligible to submit an appeal, they can write a letter to request an appeal and mail it to the IRS address on the letter they received with their appeal rights. To avoid delays, it?s important that taxpayers send their request to the address on the letter they received and not directly to the IRS Independent Office of Appeals.

Taxpayers may represent themselves or have a tax professional represent them during the appeal process. More details about who can serve as a representative is in Practice before IRS and Power of Attorney, Publication 947.

Special case procedures
Some types of appeals have their own processes including:

More information:
Taxpayer Bill of Rights 5: The Right to Appeal an IRS Decision in an Independent Forum

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Issue Number: Tax Tip 2023-79