Tax Controversy & Resolution: Appeal Proceeding Background

What Can You Expect from Appeals?

If your case qualifies for an appeal, an Appeals employee will review the issues of your case with a objective and fresh perspective and schedule a conference with you. Appeals conferences are informal and may be conducted by correspondence or telephone. Most differences are settled in these appeals without expensive and time-intensive court proceedings. Appeals will consider any reason you have for disagreement, except for moral, religious, political or constitutional arguments, conscientious objections, or similar grounds.

It is essential to provide all specifically requested and/or relevant support to the auditor or revenue officer who is assigned to your case. However, careful consideration should be taken when providing requested documentation to prevent further inquiry into additional tax issues by the IRS. Delays in providing such information to Appeals may result in your case being relayed back to the auditor or revenue officer for consideration of the new information. In which case, either action, could create delays in resolving your tax issues.

Taxpayer's Responsibilities

  • In your protest requesting appeal, list all issues with which you disagree and why, and tell us how you understand the facts and the law.

  • Give us any additional information or documentation that will be helpful to your case within the time-frame specified.

    • If presenting new information not previously provide to the auditor or revenue officer, Appeals may return your case or refer that information back to the original audit team prior to Appeals consideration.

General Timeline:

First Notice from Appeals

Normally, you can expect to hear from an Appeals employee within 60 days after the Office of Appeals receives your file. Response times from Appeals can vary, however, depending on the type of case and the time needed to review the file. If it's been more than 120 days since you filed your protest requesting an appeal, and you have not heard from the Office of Appeals, then you should contact the IRS office where your appeal request was sent.

If the associated IRS office, you sent your request, cannot provide a reason for the delayed Appeals response you have two options:

  • (1) request the IRS to contact Appeals for an approximate date when Appeals might contact you; or 

  • (2) contact the Appeals Account Resolution Specialist (AARS) function. The AARS can update you whether your case has been assigned to an Appeals employee and how to contact that employee directly.

Timeline For Resolution

The time it takes to resolve your case depends on the facts and circumstances. It may take anywhere from 90 days to a year to resolve. However, the Appeals Officer or Settlement Officer may provide a more specific timeline.

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