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You will speak directly to a tax attorney, certified public accountant, or former IRS agent, manager, tax instructor or the IRS appellate agent.
The IRS Appeal Process is the avenue to use to fight back if the IRS tax audit does not go your way.
IRS has an Administrative Appeals Process
The IRS has an administrative appeals process that works with taxpayers to try to settle tax disputes in an effort to avoid formal court hearings.
The role of IRS Audit Appeals is to make an independent review of a tax dispute and to consider the positions taken by both the taxpayer and the Service.
The Office of IRS Appeals unit strives to resolve tax disputes in a fair way and remain impartial to both parties.
The IRS will send you a report and/or letter that will explain the proposed adjustments or proposed or taken collection action.
The letter also tells you of your right to request a conference with an Appeals or Settlement Officer, as well as how to make your request for a conference.
In addition to examination adjustments, many other things can be appealed such as penalties, interest, trust fund recovery penalties, offers in compromise, liens, and levies. If you request an Appeals conference, be prepared with records and documentation to support your position.
Appeals conferences are informal meetings.
You may represent yourself or have an attorney, accountant, or an individual enrolled to practice before the IRS, represent you.
If you do not reach agreement with the Appeals or Settlement Officer, or you do not wish to appeal within the IRS, you may appeal certain actions through the courts.
 
Preparing A Request For IRS Appeals
Small Case Request
You prepare a small case request instead of a written protest if the total amount for any one tax period is $25,000 or less.
 

• Send a letter requesting Appeals consideration.

• Indicate the changes you do not agree with and the reason you don’t agree.

• For specific guidance in preparing a small case request/protest, refer to Form 12203, Request for Appeals Review.

 
Formal Written Protest
 

• Prepare a formal written protest for all of the following situations:

• If the total amount for any one tax period is greater than $25,000.

• Employee plan and exempt organization cases without regard to the dollar amount at issue.

• Partnership and S corporation cases without regard to the dollar amount at issue.

 
To prepare a formal written request for Appeals you must:
1. Include your name, address, social security number, and daytime telephone number.
2. Include a statement that you want to appeal the IRS findings to the Appeals office.
3. Include a copy of the letter showing the proposed changes and findings you don’t agree with (or the date and symbols from the letter).
4. Indicate the tax periods or years involved.
5. List all the changes you do not agree with and why you don’t agree.
6. State the facts supporting your position on any issue that you do not agree with.
7. Cite the law or authority, if any, on which you are relying.
8. Sign the written protest under the penalties of perjury.
 
You can represent yourself in Appeals, and you may bring another person with you to support your position.
 The two most Frequently Asked Questions
Question -1    I sent in my appeal request/protest. How long will it be before I hear from the Appeals office?
Answer –1   This varies, depending on the type of case you are appealing and the time needed to review the file before sending your case to Appeals.
Normally, you can expect to hear from an Appeals employee within 90 days after you file your appeal request.
If more than 90 days have gone by and you still haven’t heard from Appeals, you should contact the office where you sent your appeal request.
They can tell you when they forwarded your case to Appeals.
If they were delayed in sending your case, you would not expect to hear from Appeals until at least 90 days from that date.
If more than 90 days have gone by and there is no known delay, ask that office to contact Appeals to get a time frame for when Appeals will contact you.
After researching the Appeals data base, they can tell you if your case has been assigned to an Appeals employee, their name and number and you can contact that employee directly.
 
Question 2  – How long will it take to resolve my case once it is received in Appeals?
Answer 2 –  It depends on the facts and circumstances. It could take anywhere from 90 days to a year. Appeals continues to work towards reducing the time to resolve cases.
Your Appeals Officer or Settlement Officer can provide you with a more specific time frame.
Being a former IRS agent and teaching instructor you want to make sure you have a winnable case in appeals. Therefore I urge  you to have your case thoroughly reviewed by a tax professional to make sure that you have a winnable case in the IRS appeals process.  A good tax professional can help uses a process  and save you a boatload of money.
 
 
Appeal IRS Tax Audit with Affordable Tax Attorneys &  Former IRS