Few things are more frustrating than an IRS decision that does not add up. Fortunately, the appeals process gives taxpayers the chance to present their side of the story for independent review when they disagree with an IRS decision or action.
The IRS appeals process follows strict procedural rules and deadlines, and success often depends on understanding what the IRS expects and presenting your position clearly and persuasively. That’s why it’s critical to work with a tax professional.
East Coast Tax Consulting Group represents taxpayers in IRS appeals throughout the region. Our goal is to protect your rights, reduce unnecessary stress, and pursue the most favorable resolution available under the law. Whether you are responding to an unexpected audit result, a proposed penalty, or a collection action that threatens your income or assets, our team brings the experience needed to guide your appeal from start to finish.
Based in Boca Raton, we serve clients across South Florida, including Boynton Beach, Coral Springs, Deerfield Beach, Delray Beach, Hollywood, Plantation, Pompano Beach, Port St Lucie, and West Palm Beach, as well as taxpayers throughout the rest of the state.
With over three decades of experience, we understand what taxpayers need when facing an IRS dispute. Whether you are dealing with an audit, a penalty, or a collection issue, we offer comprehensive support, including representation throughout the appeals process.
Every engagement begins with a free consultation, during which we learn about your situation, review the IRS notices you received, and determine whether an appeal is the right path forward.
When Can You Appeal an IRS Decision?
If you receive a letter explaining a change to your tax return, a new balance due, or a proposed collection action, the notice usually outlines your appeal options. However, you don’t always get a notice. Sometimes, you have appeal options if the IRS tells you they’re going to take a certain action, or if you have waited a certain amount of time to hear back from an application. For example, if the IRS doesn’t respond to an innocent spouse request within six months, you have the right to file a petition in Tax Court.
However, there are different types of appeals for different types of situations, and they all have different deadlines and processes. It’s critical to understand which decisions qualify for appeal, which type of appeal you should enter, and the process for doing so. An experienced tax professional can represent you through the process.
First, let’s look at which types of IRS decisions you have the right to appeal. This is not an exhaustive list, and if you’re dealing with another concern, you should reach out for assistance today.
Audit Results
If an audit leads to additional tax, penalties, or adjustments you disagree with, you can request an administrative appeal or audit reconsideration. Many taxpayers choose to appeal audit findings because it provides a chance to present additional documentation or correct misunderstandings before the tax assessment becomes final.
Penalty Assessments
The IRS may assess penalties for late filing, late payment, accuracy issues, or other concerns. These penalties can often be challenged through the appeals process, especially when there is reasonable cause or when the penalties were not correctly applied. Learn more about IRS penalty abatement.
Liens and Levies
If you received a Notice of Federal Tax Lien or a Final Notice of Intent to Levy, you may have the right to challenge the action through a Collection Due Process hearing. This step can prevent enforced collection and give you time to pursue alternatives. However, depending on timing and other factors, you may need to appeal through an equivalent hearing or with the Collection Appeals Program (CAP).
Rejected installment agreements or Offers in Compromise
If the IRS denies your request for an installment agreement or an Offer in Compromise, you may be able to appeal that decision. If you’re going to appeal an installment agreement rejection, you should understand why the IRS rejected your initial application so you can present the strongest appeal possible. Similarly, if appealing a rejected OIC, you also need to understand the basis for rejection so you can mount a strong appeal.
Trust Fund Recovery Penalty Determinations
If the IRS proposes the Trust Fund Recovery Penalty, you have the right to challenge the proposed penalty through an appeal. These cases are high stakes because they hold individuals personally responsible for payroll tax liabilities. If you need help fighting this penalty, our firm assists with preparing evidence, addressing responsibility factors, and presenting your position to Appeals.
If you have received an IRS notice and are unsure whether you qualify for an appeal, we can review your situation and advise you on your options. Acting quickly is essential because most appeals must be filed within a limited time frame.
IRS Appeals Processes We Handle
The IRS offers several appeal avenues, and knowing which one applies to your situation is essential. Each process serves a different purpose, follows specific rules, and carries its own set of deadlines. East Coast Tax Consulting Group represents taxpayers in all major IRS appeal programs and ensures that your case is prepared and presented correctly at every stage.
Collection Due Process Hearings
A Collection Due Process (CDP) hearing gives you the right to challenge specific IRS collection actions before they move forward. If you received a Final Notice of Intent to Levy or a Notice of Federal Tax Lien, you may request a CDP hearing to stop enforced collection while you pursue alternatives. Typically, you only have 30 days from the date the notice was sent to request a CDP hearing. Our firm regularly assists taxpayers during CDP hearings, and we can provide the guidance you need.
Equivalent Hearing
When you get the right to request a CDP hearing, you also get the right to request an Equivalent Hearing. The Equivalent Hearing comes into play if you miss the deadline for the CDP. You have up to a year to request an Equivalent Hearing.
Certain processes are similar, but while you’re waiting for an Equivalent Hearing, the IRS is not required to stop collection actions. Additionally, if you disagree with the results of the hearing, you cannot go to Tax Court.
Collection Appeals Program
The Collection Appeals Program allows taxpayers to dispute collection actions, including liens, levies, termination of installment agreements, and seizures. CAP is often faster than a CDP hearing and can be helpful when you need the IRS to reconsider a collection decision quickly.
However, one drawback is that you cannot appeal the results of the CAP hearing, but in contrast, you can petition the Tax Court if you disagree with the results of a CDP hearing.
Audit Appeals
If you have already gone through an audit but believe the results are incorrect, you can appeal. You must appeal before the taxes are assessed. If you disagree with the results of the appeal, you can take the case to Tax Court.
Audit Reconsideration
Alternatively, once the taxes are assessed after an audit, you may be able to request audit reconsideration, but only if the taxes have not been paid yet. This option is helpful when new documentation becomes available or when you did not have the chance to fully respond during the original audit.
Our team can help you determine whether reconsideration or an audit appeal is the better approach.
No matter which program applies to your situation, the appeals process is designed to give taxpayers a fair and independent review. Our role is to help you take full advantage of that opportunity and position your case for the strongest possible outcome.
Why Work with a Tax Professional for Appeals
IRS appeals are meant to provide an independent review, but that does not make the process simple. Each type of appeal has its own eligibility rules, required forms, timelines, and evidentiary standards. The IRS Appeals Office also expects taxpayers to present a clear and well-supported position. When information is incomplete or arguments are not framed correctly, the appeal is more likely to be denied.
Working with an experienced tax professional gives you a meaningful advantage. Our team understands how the IRS evaluates appeals, how to prepare documentation that meets the agency’s expectations, and how to explain your position in a way that supports a favorable outcome. We also know how to identify procedural errors, negotiate practical alternatives, and guide cases that may require multiple stages of review.
Deadlines are especially important in appeals. A missed deadline can permanently limit your right to challenge the IRS decision or to prevent collection actions from beginning. When you work with us, we manage these timelines for you, prepare the required filings, and ensure that your case is presented professionally from the start.
Most taxpayers handle an appeal only once in their lifetime, while we manage these cases every day. That experience helps you avoid costly mistakes and increases the chances of resolving your tax issue fairly and efficiently.
Potential Outcomes of an IRS Appeal
An IRS appeal gives you the chance to correct the record, present additional information, and work toward a solution that is more reasonable than the IRS’s initial decision. While every case is unique, many taxpayers experience significant improvements once their matter is reviewed by the Appeals Office. The goal of Appeals is to resolve disputes fairly, which often opens the door to outcomes that were not available at earlier stages.
Some of the possible results include:
Reduction or Elimination of Tax Debt
If the IRS overstated your liability or overlooked documentation, an appeal can correct the amount you owe. Appeals Officers can adjust proposed assessments when the evidence supports a lower figure.
Penalty Removal or Reduction
Many penalties can be challenged during the appeals process. When you have reasonable cause, or when the penalty was applied incorrectly, Appeals may agree to reduce or remove it entirely.
Release of Liens or Levies
If you are facing a federal tax lien or levy, a successful appeal may result in the release of the action. This can help protect your wages, bank accounts, business revenue, or property.
Approval of a Payment Plan or Offer in Compromise
If the IRS denied your installment agreement request or Offer in Compromise, Appeals may overturn that decision. Appeals Officers can reconsider your financial information and may approve a resolution that better fits your situation.
Although not every appeal results in complete relief, many taxpayers achieve more manageable outcomes by presenting a strong and well-supported case. Our role is to help you pursue the best possible resolution based on your facts and the options allowed under IRS guidelines.
Our IRS Appeals Process
Here’s what to expect when you hire us to help you with the IRS appeals process.
Consultation and case review
A strong appeal begins with a clear understanding of the issues and the steps required to address them. We start with a free consultation to review your IRS notice, go over the facts of your case, and learn what you hope to achieve. This helps us determine whether an appeal is the right approach and ensures you have a realistic picture of the process.
Gathering and preparing evidence
Once we move forward, our team will gather the documentation needed to support your position. Appeals Officers rely heavily on organized and complete records, so we help you collect financial statements, correspondence, and any other materials that clarify the facts. We evaluate what the IRS will consider relevant and prepare your supporting information in a way that presents your case clearly.
Filing the appeal and meeting deadlines
From there, we handle all required filings and deadlines. Each appeal program has its own rules and timelines, and missing even one deadline can jeopardize your rights. We prepare the written protest or appeal request, complete the necessary forms, and submit everything to the correct IRS office.
Representation during appeals conferences
If your case proceeds to a conference, we represent you throughout the discussions with the Appeals Officer. These meetings are your opportunity to explain your side of the story and negotiate a fair resolution. Our role is to present your position effectively and work toward an outcome that reflects your facts and circumstances.
Pursuing further relief if needed
If the Appeals Office cannot resolve the dispute, we will discuss additional options with you, including further administrative review or possible referral to Tax Court. Throughout the process, our focus remains on protecting your interests and helping you reach the best possible resolution.
Understanding IRS Appeal Timelines
IRS appeals move on strict schedules, and missing even one deadline can limit your options. Most appeals must be filed within 30 days of receiving the IRS notice, although some programs have shorter or slightly longer time frames.
The Appeals Office will then review your case and schedule a conference, which can take several weeks or months, depending on complexity. While the process is not immediate, acting quickly at the start protects your rights and prevents enforced collection.
If you received a notice, the safest approach is to begin the appeal process as soon as possible.
Get Help With Your IRS Appeal Today
If you received an IRS notice and believe the decision is incorrect or unfair, the time to act is now. Appeals have firm deadlines, and waiting too long can limit your ability to challenge the IRS or stop collection efforts.
East Coast Tax Consulting Group is here to review your situation, explain your options, and guide you through every step of the appeals process. Contact us today to schedule your free consultation and protect your rights, moving toward a fair resolution with confidence.
