The IRS Doesn’t Always Get the Last Word: An Introduction to IRS Appeals
Most clients believe that once the IRS makes a decision, the matter is over. Case closed. Hand over your money.
Except that's not true. IRS collections is not the final judge, jury, and executioner. There’s an entire independent office dedicated to second chances—and knowing about it can make or break your client’s finances.
I’m talking about the IRS Appeals process—the overlooked resolution procedure that gives taxpayers an opportunity to challenge IRS decisions without spending on taking the case through court.
Every year, tens of thousands of taxpayers file appeals. Many which end in fairer outcomes, overturned IRS decisions, or restructured collection agreements.
For professionals like you—CPAs, attorneys, advisors, realtors, and brokers—knowing how appeals work could be the difference between a deal closing or collapsing and a client rebuilding or breaking down.
Why It Matters
If you don’t know that there’s a legitimate path to challenge IRS decisions, your client may end up paying more than they should or watch their financial circumstances implode.
And appeals is built exactly for these moments.
Let's walk through five things every professional needs to know about IRS Appeals.
1. Appeals Is Independent (Actually)
The IRS Independent Office of Appeals isn’t staffed by the same agents from the IRS. Their mandate is to review disputes impartially. That independence gives taxpayers a shot at being heard by someone who doesn’t have skin in the game.
2. The Most Common Cases
In any given year, upwards of 75,000 cases are handled by Appeals.
The biggest buckets:
Collection Due Process (CDP) cases: disputes over liens and levies.
Audit cases: disagreements over income, payroll, or excise taxes.
Penalty disputes: late-filing penalties, accuracy penalties, and more.
Rejected Offers in Compromise: thousands of taxpayers every year try again through Appeals.
In other words, if the IRS says “no,” Appeals gives you an opportunity to get a different determination.
3. Timing Is Critical
Most appeals have a 30-day deadline from the notice date. Miss it, and you're out of luck. For your clients, missing the deadline isn’t just costly—it may be fatal to their options.
4. The Process Isn’t as Intimidating as Court
Appeals officers handle disputes through informal conferences—often by phone or video call. They review both sides, weigh the law, and work toward a resolution. For many clients, this is far less intimidating than dealing with the attorneys and the judge in Tax Court.
5. The Stakes Are High for Your Clients
A wage garnishment, a lien issued or an unfavorable audit determination. These scenarios aren’t hypothetical—and appeals is available. For you, it could mean the IRS giving back $50k from a bank levy or releasing a lien on their home.
TL;DR
⏩ The IRS isn’t the last word—Appeals gives taxpayers a second chance.
⏩ The Appeals Office is independent and impartial and resolves thousands of cases every year.
⏩ Appeals cover audits, liens, levies, penalties, and rejected OICs.
⏩ Deadlines are tight—usually 30 days.
⏩ The process is administrative, not courtroom drama.
➥ Contact Attorney Stephen A. Weisberg for a free Tax Debt Analysis.
Contact Me Here: https://www.weisberg.tax/contact-1
Email: sweisberg@wtaxattorney.com
Phone/Text: (248) 971-0885
Address: 300 Galleria Officentre, Suite 402, Southfield, MI 48034
