IRS Appeals and Protests

After an IRS audit, if the taxpayer disagrees with the outcome, the taxpayer may appeal his or her case to the Appeals Office of the IRS, rather than head straight to court. In that case, the taxpayer requests an Appeals conference, which is an informal meeting with the Appeals Office personnel, within the time limits specified in the audit findings letter. In most cases, when requesting an Appeals conference, the taxpayer must file a written protest with the Appeals Office of the IRS.

If the Appeals conference did not resolve all of the taxpayer’s issues, the taxpayer may take his or her case to the U.S. Tax Court, the U.S. Court of Federal Claims, or a U.S. District Court, after satisfying certain procedural and jurisdictional requirements.

Whether the taxpayer proceeds with the informal Appeals conference or takes his or her case directly to court, it is imperative that the taxpayer seek counsel by an experienced attorney at the earliest possible time. Doing so can protect the taxpayer’s rights while also ensuring the best possible outcome.

As an attorney for over the last 40 years, I have earned a successful track record in high stakes matters and have argued before the United States Supreme Court as well as other federal courts throughout the country.  If you have questions or concerns about an appeals matter, I invite you to contact me directly to discuss it at 888-700-1555 or  You will discuss your concerns with me personally—never an associate or a paralegal.  In addition, you should know that your contact with me, and with my firm, is privileged under the law, regardless of whether or not you decide to retain my firm to represent you.

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