Appealing an IRS Audit Determination

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Publication date: 08.07.2025

Reading time: 4 minutes

Number of views: 18

№ Stage Term (days) Cost

1
Stage 1. Initial Assessment and Consultation
5 $484.00
Stage 1. Initial Assessment and Consultation

Attorney's Actions:
- Analysis of IRS notice (Notice of Deficiency, Examination Report etc.)
- Verification of appeal filing deadlines
- Case prospects evaluation: factual basis, procedural violations, inaccuracies in findings
- Providing written consultation on potential appeal options (formal complaint, negotiations, tax petition to US Tax Court)
Estimated Cost: $300-$700 (one-time consultation or hourly rate $150-$300/hour)
2
Stage 2. Preparation and Submission of Response to IRS Letter or Notice of Deficiency
14 $2,420.00
Stage 2. Preparation and Submission of Response to IRS Letter or Notice of Deficiency

Attorney's Actions:
- Preparation of official written response (Protest Letter or Statement of Disagreement)
- Gathering of supporting documents, evidence, and corrections
- Submission of response to the appropriate IRS department within the established deadline (typically 30 days from receipt of notice)
3
Stage 3. Negotiations with IRS (Appeals Office or Revenue Agent)
60 $6,050.00
Stage 3. Negotiations with IRS (Appeals Office or Revenue Agent)

Attorney's Actions:
- Managing communication with IRS auditor or appeals officer
- Providing additional documentation upon request
- Presenting client's position during meetings, phone calls, or written explanations
- Negotiating possible Settlement Agreement
4
Stage 4. Filing a Complaint with the U.S. Tax Court if the Dispute is Not Resolved
365 $12,100.00
Stage 4. Filing a Complaint with the U.S. Tax Court if the Dispute is Not Resolved

Attorney's Actions:
- Preparing and filing a petition (Tax Court Petition) with the U.S. Tax Court within the 90-day deadline from the date of the Notice of Deficiency
- Gathering and submitting evidence, expert opinions
- Representing the client's interests at pre-trial conferences and court hearings
Estimated Cost:
Preparing the petition: $1,500–$3,000
Full court representation: $10,000–$30,000+
5
Stage 5. Case Closure and Result Implementation
21 $1,210.00
Stage 5. Case Closure and Result Implementation

Attorney's Actions:
- Reviewing the final IRS or court decision
- Assisting with payment or refund processing (if the IRS agreed to reduce liabilities or issue a refund)
- Filing amended returns or refund claims

In general

465 $22,264.00

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Preparing a Formal Protest – "IRS audit appeal"

The appeal process begins with preparing an official protest in the form of a written request ("formal protest letter") within 30 days of receiving the Notice of Determination or Final Notice. The protest must include:

taxpayer information and copy of IRS decision
description of disputed items and appeal amount
substantiated arguments with references to facts and legislation

For amounts under $25,000, a simplified "small case request" is possible without formal protest, but with clear position statement.

How does the IRS appeals process work?

The Office of Appeals is an independent IRS structure that resolves disputes without going to court. After receiving a protest:

An appeals officer organizes a conference (in person, by phone or correspondence)
Reviews taxpayer arguments and IRS position
Offers settlement or confirms initial IRS decision

If the decision stands - the taxpayer may file in court (Tax Court, U.S. District Court or Court of Federal Claims).

Benefits of professional representation - "appealing an IRS audit"

Strongest possible protest: attorneys/CPAs develop substantiated legal positions and negotiate with appeals officers
Stress-free communication: spares you from personal confrontation and confusing formalities
Potential to minimize penalties and interest, possibly even full tax cancellation
Rights protection: helps meet appeal deadlines (30 days) and avoid rejections due to errors

Frequently asked questions about "filing an appeal with the IRS Office of Appeals"

Question	Answer
What can be appealed?	Audit results, penalties, liens, property seizures, rejected applications, etc.
What if Appeals denies?	You may proceed to court in Tax Court or other jurisdiction
How long does the process take?	Typically several months, depending on case complexity and parties' readiness

Why choose our legal services?

Our Consultant team consists of experienced tax attorneys and CPAs who:

promptly prepare Formal IRS Audit Appeal meeting all requirements
negotiate with appeals officers to reduce assessments
ensure strict deadline compliance (don't miss the 30-day deadline)
if denied, prepare court documents for Tax Court, District Court or Federal Claims

We provide complete legal representation: from request preparation to court filing if needed. Our approach saves clients time, money and stress while legally reducing tax liabilities.

Ready to appeal an IRS decision?

Submit your request now - Consultant will contact you for initial consultation to evaluate your situation, discuss potential benefits and develop a clear action plan. We're your reliable partner against the IRS!

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Appealing an IRS Audit Determination

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Stage 1. Initial Assessment and Consultation

Stage 2. Preparation and Submission of Response to IRS Letter or Notice of Deficiency

Stage 3. Negotiations with IRS (Appeals Office or Revenue Agent)

Stage 4. Filing a Complaint with the U.S. Tax Court if the Dispute is Not Resolved

Stage 5. Case Closure and Result Implementation

Preparing a Formal Protest – "IRS audit appeal"

How does the IRS appeals process work?

Benefits of professional representation - "appealing an IRS audit"

Frequently asked questions about "filing an appeal with the IRS Office of Appeals"