IRS has an Office of Appeals (OOA) that operates as an “independent” organization within the IRS. The goal of the OOA is to help Taxpayers resolve their tax disputes through an informal, administrative process, and through weighting IRS’ risks of litigation. The OOA aims to resolve tax controversies “without litigation” avoiding expensive and time-consuming court proceedings. The OOA will assign an appeals officer or a settlement officer to review the strengths and weaknesses of the position(s) taken by the Taxpayer. The reviews may be conducted by correspondence, telephone or at a personal meeting.
Written by Foodman CPAs & Advisors
Who may appeal to the OOA?
- A Taxpayer that has received a letter from the IRS explaining the Taxpayer’s right to appeal a decision taken by the IRS.
- A Taxpayer that does not agree with a decision made by the IRS.
- A Taxpayer that is not signing an agreement form sent to him/her by the IRS.
Who may NOT appeal to the OOA:
- A Taxpayer that received correspondence from the IRS with a bill without mention of Appeals.
- A Taxpayer that did not provide all the information to support his/her position to an IRS examiner during an audit.
- A Taxpayers whose only concern is an inability to pay the amount owed.
Taxpayers with IRS appeal rights may work directly with the IRS or be represented