Because people sometimes disagree on tax matters, the Internal Revenue Service has an appeals system. Most differences can be settled within this system without expensive and time-consuming court trials. However, your reasons for disagreeing with the IRS must come within the scope of the tax laws. For example, you cannot appeal your case based only on moral, religious, political, constitutional, conscientious, or similar grounds.
In most instances, you may be eligible to take your case to court if you do not reach an agreement at your appeals conference, or if you do not want to appeal your case to the IRS Office of Appeals. You can appeal an IRS tax decision to a local Appeals Office, which is separate from and independent of the IRS office taking the action you disagree with. The Appeals Office is the only level of appeal within the IRS. Conferences with appeals personnel are held in an informal manner by correspondence, by telephone, or at a personal conference.
If you want an appeals conference the IRS generally sends specific instructions that are including in a notice you received, or you may file your appeal directly with the local Appeals Office servicing your area. When they receive your request the Appeals Office will arrange a conference at a mutually convenient time and place.
At the appeals conference you must be prepared to discuss all the disputed issues, any issues not brought up at appeal may not be appealed further or taken to tax court. Many dispute with the Internal Revenue Service are settled in appeals, however if an agreement cannot be reached you may then take your case to tax court.
Any collection activity or threat of collection activity made by the Internal Revenue Service may be appealed. Additionally, any adverse decision or determination by the IRS against you as a taxpayer, either through the addition of assessed tax, penalties and interest through an examination or audit, or otherwise, may be appealed. When making some types of appeals the taxpayer may forfeit his or her right to take the matter further to tax court if they do not prevail in appeals. However in most instances the final word on all tax disagreements will be a ruling by the tax court.
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