Can I appeal an IRS audit result I disagree with?
Yes, you have the right to appeal IRS audit results through the IRS Office of Appeals (now called the Independent Office of Appeals). After the audit, if you disagree with the proposed changes, you'll receive a 30-day letter outlining the adjustments. You can file a written protest within 30 days requesting an Appeals conference. For proposed changes under $25,000, you can request a Small Case Appeal using Form 12203 without a formal written protest. For amounts over $25,000, you must file a detailed written protest including: your name and contact information, a statement that you want to appeal, a copy of the 30-day letter, the tax years involved, a list of each item you disagree with and why, facts supporting your position, and the law or authority supporting your position. Appeals officers are independent from the examination division and have authority to settle cases based on litigation risk. About 85% of cases that go to Appeals reach some form of settlement. If Appeals doesn't resolve your case, you can petition the U.S. Tax Court within 90 days of receiving a statutory Notice of Deficiency (90-day letter).
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