The Appeals Process
Taxpayers who, after audit of their tax returns, disagree with a proposed change in their tax liabilities are entitled to an independent review of their cases. Taxpayers are able to seek an immediate, informal appeal with the Appeals Office. If, however, the dispute arises from a field audit and the amount in question exceeds $10,000, a taxpayer must submit a written protest. Alternatively, the taxpayer can wait for the examiner's report and then request consideration by the Appeals Office and file a protest if necessary. Taxpayers may represent themselves or be represented by an attorney, accountant, or any other adviser authorized to practice before the IRS. Taxpayers can forgo their right to the above process and await receipt of a deficiency notice. At this juncture, taxpayers can either (1) not pay the deficiency and petition the Tax Court by a required deadline or (2) pay the deficiency and file a claim for refund with the District Director's office. If the claim is not allowed, a suit for refund may be brought either in the District Court or the Claims Court.
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