Contesting an IRS Audit Determination

IRS Audit in the Office of Appeals

If a client is thinking about appealing an adverse IRS audit determination, the IRS Office of Appeals is an independent office within the Revenue Service that is separate from the exam and collection divisions.

Normally, a taxpayer can request an appeal by submitting a written protest or statement setting forth the issues in dispute and the reasons for disagreement. Cases in Appeals last on average seven to eight months, starting from the date that Appeals receives the case until it is finally resolved or closed. This time frame applies to cases received from the exam or collection division that have not been petitioned to the Tax Court. The Appeals Office has the authority to lower the tax owed to settle the dispute. It also weighs the probable outcomes if the case were to end up in court and can offer a settlement based on that calculation. Even though many cases in Appeals end up meriting a compromise, some do not. 

 

Authored by:

Dr. John Connors, J.D., CPA, LLM

Tax Educator’s Network, Inc.

[email protected]

For subscription information on Dr. John Connors’ educational materials, click here.

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