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Appealing Examination Issues

Before you prepare a request for Appeals, refer to the Appeals homepage to decide if Appeals is the place for you.  If you decide you want to present your dispute to Appeals, you will need to prepare a request for Appeals and mail it to the office that sent you the decision letter.
Preparing A Request For 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:

  • Include your name, address, social security number, and daytime telephone number.
  • Include a statement that you want to appeal the IRS findings to the Appeals office.
  • 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).
  • Indicate the tax periods or years involved.
  • List all the changes you do not agree with and why you don’t agree.
  • State the facts supporting your position on any issue that you do not agree with.
  • Cite the law or authority, if any, on which you are relying.
  • 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. If you want to be represented by someone, the person you choose to represent you must be an attorney, a certified public accountant, or an enrolled agent authorized to practice before the IRS. If you plan to have your representative talk to us without you, we need a copy of a completed power of attorney Form 2848, Power of Attorney and Declaration of Representative

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