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, you can contact the local Taxpayer Advocate office for help. Do not send your protest directly to the IRS Independent Office of Appeals (Appeals); this will only delay the process and prevent the appeals from considering your case. This telephone contact will generally be made in cases where the taxpayer has filed an application with the court as a result of a letter from the IRS Correspondence Examination Unit or the Underreporting Income Unit. Mail your appeal request directly to the person or IRS office that made the determination you are seeking to appeal.
The tax decision made by the examiner can be appealed to a local appeals office, which is independent and independent of the IRS Office that conducted the review. Instructions for requesting a meeting with an appeals officer are contained in the proposed fiscal adjustment letter. Appeals can contact the Tax Court and if they haven't had a previous opportunity to try to resolve their case through appeals. The IRS Independent Office of Appeals seeks to resolve disputes between taxpayers and the IRS without the need for litigation.
If the IRS determines that you did not deliberately take these steps, you may be held personally responsible for a penalty equal to the full amount of tax that was not paid, plus interest. Cases received directly from Compliance that have not been filed with the Tax Court are called “unfiled cases”. Only attorneys, certified public accountants, or enrolled agents can represent a taxpayer on appeals. Appeals cannot help you resolve your tax issues until the IRS office dealing with your case has processed your appeal request.
Appeals recognizes that some taxpayers may be concerned that a caller who claims to be from IRS Appeals actually comes from Appeals. If a conference is requested, the examiner will send the conference request letter to the appeals office to organize a conference at a convenient time and place. If you are appealing the commitment offer for denial of doubt of liability (DATL), the total amount for each tax period includes the total of unpaid taxes, the penalty, and the interest due.