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.

If your examination or other adjustment was conducted through a personal interview with an IRS employee, the employee will explain your appeal rights to you. If you disagree with the findings, you may request a meeting with the interviewer's supervisor. If you still do not reach an agreement, or if the examination or other adjustment was conducted through correspondence, the IRS will provide you with a report and/or letter that explains the proposed adjustments and informs you of your right to request a conference with an appeals officer. The letter will also tell you how to make your request. If you request an appeals conference, be prepared to support your position.

In addition to examinations, many other things can be appealed. Among them are penalties, including the trust fund recovery penalty, offers–in–compromise, employment tax adjustments, liens, levies, seizures, installment agreements, collection due process notices, abatement of interest and other claims.

Appeals conferences are informal meetings. Your conference may be face-to-face, or by telephone, or by correspondence, at your choice. You may represent yourself at an Appeals conference; or, if you want, you may have an attorney, a certified public accountant, or an individual enrolled to practice before the IRS represent you. If you do not reach an agreement with the appeals officer, or you do not wish to appeal within the IRS, you may take your appeal into 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 (PDF), Your Appeal Rights and How To Prepare A Protest If You Don't Agree, and Publication 556 (PDF), Examination of Returns, Appeal Rights and Claims for Refund. Also, Publication 1660 (PDF), Collection Appeal Rights, discusses how you can appeal those actions.

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