IRS Audit Appeals

Appealing IRS Examination Findings

An audit appeal concerns the IRS's proposed changes to your tax return. The notice you receive identifies the available response procedure. Our team reviews the examination report, supporting records, and disputed adjustments to help you prepare your case.

Administrative Review

A 30-day letter generally offers an opportunity to request a conference with the IRS Independent Office of Appeals. Follow the instructions and deadline in your letter. A written protest may be required, depending on the case.

Our attorneys can organize evidence, explain your position, and represent you in discussions about the disputed tax issues.

Notice of Deficiency and Tax Court

A notice of deficiency provides a separate opportunity to petition the U.S. Tax Court. The filing period is generally 90 days, or 150 days when the notice is addressed to a person outside the United States. Review the exact notice and applicable rules promptly; discussions with the IRS do not automatically extend this deadline.

If you do not file a timely petition, the IRS can generally assess the proposed deficiency. Other remedies may depend on the circumstances.

Prepare for Your Consultation

• The IRS notice, envelope, and examination report
• The tax returns and years involved
• Documents supporting disputed income, deductions, or credits
• Prior correspondence with the IRS

An Offer in Compromise rejection follows a different procedure. See our dedicated Offer in Compromise appeals page.

Further information: IRS Independent Office of Appeals and U.S. Tax Court definitions.

General information only. Your notice and circumstances determine the procedures and deadlines that apply.