List the points of disagreement and the reasons why you disagree with the changes proposed by the IRS in the review (audit). Mail your appeal request directly to the person or IRS office that made the determination you are seeking to appeal. Before or after filing a return or other interaction with the IRS, you seek tax security or advice on tax results under a U. You and others (from your industry or even from other sectors) would benefit from having a team of IRS professionals review the issue and provide guidance.
There are other exclusions and requirements (such as those related to international issues) on the IRS PFA website. You hope that having the Appeals Department review the matter before the examination or collection case is completed will help you and the IRS resolve the other issues in the case. The IRS examination or collection office that conducted a tax assessment or initiated a collection action will consider your protest and will attempt to resolve the disputed tax issues. Certain requests for resolution by letter have lower fees, including those that relate to accounting periods and changes in methods and requests for extension of time for regulatory elections that do not meet the requirements of section 301 9100-2.It is issued only when a determination can be made based on rules clearly established in a law, a tax treaty, the regulation, a conclusion of a tax resolution, or a court opinion or decision that represents the position of the IRS.
The IRS Independent Office of Appeals is here to resolve disputes, without litigation, in a way that is fair and impartial to the government and to you. Cases received directly from Compliance that have not been filed with the Tax Court are called “unfiled cases”. For additional information on the structure and leadership of the IRS Independent Appeals Office, see the appeals organization graphic in PDF. If you've had difficulty dealing with the IRS or have questions about your tax issues that the IRS hasn't been able to resolve after several attempts, you can contact the local Taxpayer Advocate office for help.
The program helps taxpayers and the IRS avoid the financial and time costs of resolving issues on a case-by-case basis during tax exams. An AIR agreement is a closing agreement between the IRS and taxpayers within the framework of the compliance program for large companies related to one or more specific issues that arise from an audit of taxable periods that end before the date of the agreement. Appeals cannot help you resolve your tax issues until the IRS office dealing with your case has processed your appeal request.