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IRS Appeals
Challenge unfavorable IRS decisions through the independent Appeals Office.
Talk To A Real Tax Attorney
One honest conversation. You'll hang up knowing exactly what the IRS can — and can't — do to you, and how we'll stop them.
Call (877) 829-5267Tax Attorney · Villanova University School of Law · Admitted in Delaware, New Jersey, United States Tax Court
The Truth About IRS Appeals — And What To Do Right Now
If you disagree with an IRS decision — whether from an audit, collection action, or rejected Offer in Compromise — you have the right to appeal to the IRS Independent Office of Appeals.
The Appeals process is often where the best outcomes happen. Appeals officers have broad authority to settle cases, and they're motivated to resolve disputes without litigation.
McCauley Law Offices has extensive experience before the IRS Appeals Office, including Collection Due Process (CDP) hearings, audit reconsiderations, and Offer in Compromise appeals.
Types of IRS Appeals
Collection Due Process (CDP) Hearings
When the IRS sends a Final Notice of Intent to Levy (LT11) or a Notice of Federal Tax Lien filing, you have 30 days to request a CDP hearing. This is one of the most powerful taxpayer rights because:
- All collection activity stops while the hearing is pending
- You can propose alternative resolution — installment agreements, OIC, CNC status
- If you disagree with the Appeals Officer's decision, you can petition the U.S. Tax Court
Audit Appeals
If you disagree with an audit examiner's findings, you can request an appeal before agreeing to pay. You'll file a written protest outlining your position, and an Appeals Officer will review the case independently.
Offer in Compromise Appeals
Rejected OIC? You can appeal within 30 days using Form 13711. We regularly overturn OIC rejections by presenting additional financial documentation and addressing the examiner's specific concerns.
What Makes Appeals Different From the Regular IRS
The Appeals Office operates independently from the IRS examination and collection functions. Appeals Officers:
- Consider the hazards of litigation — they factor in what might happen if the case goes to Tax Court
- Have authority to settle cases that examiners can't
- Are trained to be impartial — they're not trying to maximize the IRS's position
- Can consider new evidence not presented during the initial process
People Just Like You Have Sat In This Exact Chair
They were terrified. They were ashamed. They thought they were the only one. Then they made one phone call — and everything changed.
Rejected Offer in Compromise Overturned
A client's $15,000 Offer in Compromise was rejected by the examining unit. We appealed, presented additional financial evidence, and the Appeals officer approved a $12,000 settlement on a $98,000 debt.
Audit Reversed at Appeals
An IRS examiner assessed $84,000 in additional tax against a Bryn Mawr small-business owner after disallowing virtually all Schedule C deductions. We protested to Appeals, presented the substantiation the auditor had ignored, and the deficiency was reduced to $6,200.
CDP Hearing Stops Levy and Secures CNC
After a CP90 notice, we filed a timely CDP request for a Delaware County client, stopped the proposed levy in its tracks, and used the hearing to establish currently not collectible status — protecting income while the underlying balance was resolved.
That Letter In Your Hand? Here's What It Really Means.
The IRS writes notices in code on purpose. If any of these landed in your mailbox, irs appeals is exactly how we fight back — and the clock is already ticking.
This is the absolute final warning. The IRS will begin seizing your wages, bank accounts, and property within 30 days.
Deadline: 30 days
This is your legal right to challenge the IRS in Tax Court before paying. Miss this deadline and you lose that right.
Deadline: 90 days
The IRS believes you didn't report all your income. They've received information (W-2s, 1099s) that doesn't match your return.
Deadline: 30 days
You're being audited. The IRS wants to examine specific items on your tax return and is requesting documentation.
Deadline: Varies (typically 30 days)
CP210 (and the related CP220) notifies a business that the IRS has adjusted its tax account — typically a math correction, a credit transfer, or a penalty assessment on a payroll or business return. The notice shows the adjusted balance and may demand additional tax, penalties, and interest.
Deadline: 30 days
CP90 (individuals) and CP297 (businesses) are the IRS's statutory Final Notice of Intent to Levy. After 30 days the IRS can legally seize wages, bank accounts, retirement funds, and Social Security payments.
Deadline: 30 days to request CDP hearing
CP2501 is the IRS's first letter telling you third-party income data (W-2s, 1099s, K-1s, 1099-NECs) doesn't match what you reported. It's the prelude to a CP2000 adjustment if you don't respond.
Deadline: 30 days
Every Day You Wait, The IRS Wins A Little More.
Penalties stack. Interest compounds. Legal options quietly disappear. One free call ends the spiral.
Exactly How We Take This Off Your Shoulders
The hardest step is the first one. Everything after that, we carry for you. No surprises. No runaround. No lectures.
- 1
Calendar every appeal deadline
30-day letter, CDP 30-day, CAP, equivalent hearing — we map each window the day we open the file so no right is forfeited.
- 2
File the protest the right way
Formal written protest with statement of facts, legal authority, and disputed adjustments — exactly what Publication 5 requires.
- 3
Build the litigation hazard file
Appeals officers settle based on hazards. We assemble the documents, case law, and witness statements that show the IRS would likely lose if forced to court.
- 4
Negotiate the conference
We attend the Appeals conference (in person, by phone, or virtual), present the case, and negotiate a Form 870-AD or collection alternative.
- 5
Lock in the result
Closing agreement, Tax Court petition if needed, or proper post-Appeals collection setup — the case isn't done until the resolution is documented and executed.
Trusted by Thousands of Taxpayers
Real results from real clients
Robert M.
Sandra L.
Michael T.
Jennifer K.
David R.
Maria G.
Thomas W.
Patricia H.
James C.
Robert M.
Sandra L.
Michael T.
Jennifer K.
David R.
Maria G.
Thomas W.
Patricia H.
James C.
Robert M.
Sandra L.
Michael T.
Jennifer K.
David R.
Maria G.
Thomas W.
Patricia H.
James C.
Robert M.
Sandra L.
Michael T.
Jennifer K.
David R.
Maria G.
Thomas W.
Patricia H.
James C.
"McCauley Law resolved my $180,000 IRS debt for a fraction of what I owed. I was facing wage garnishment and bank levies — they stopped everything and negotiated an incredible settlement."
Robert M.
Philadelphia, PA
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The Questions Keeping You Up At Night — Answered
Other Ways We Shut The IRS Down
Offer in Compromise
Settle your tax debt for less than what you owe through IRS settlement programs.
Installment Agreement
Set up manageable monthly payment plans to pay off your tax debt over time.
Currently Not Collectible
Prove financial hardship to temporarily halt IRS collection activity.
Penalty Abatement
Remove or reduce IRS penalties through first-time abatement or reasonable cause.
One Phone Call. Or Another Sleepless Night.
Stop Letting The IRS Own Your Mornings.
You already know what happens if you do nothing. Pick up the phone for a free, confidential conversation with a real tax attorney — 30+ years inside the IRS playbook — and finally start fighting back.
Call (877) 829-5267 NowPrimary Sources & Authority
We cite the underlying IRS publications and statutes so you can verify everything on this page.