Overview of the Appeals Process
The goal of the Appeals Office is to settle as many cases as possible within the broad guidelines of its Mission Statement:
The Appeals mission is to resolve tax controversies, without litigation, on a basis which is fair and impartial to both the Government and the taxpayer and in a manner that will enhance voluntary compliance and public confidence in the integrity and efficiency of the Service.
Even though much of the work of Appeals comes from examinations, its jurisdiction has expanded over the last few years. In examination cases, the taxpayer receives the 30-day letter. This letter is accompanied by the Revenue Agent Report and gives the taxpayer 30 days to request an Appeals conference. In most cases, the taxpayer is required to file a protest describing the taxpayer’s position. If the taxpayer does not request an Appeals conference, then the IRS will send the taxpayer a notice of deficiency. If the taxpayer files a petition with the Tax Court, and has not had an Appeals conference, the IRS will send the case to Appeals to investigate a possible settlement. In other types of cases, the IRS will send the taxpayer a letter advising the taxpayer of his right to an Appeals and giving the taxpayer a time limit in which to request an Appeals conference. You file the protest as stated in the letter from the IRS and within the 30-day period.