IRS Independent Office of Appeals: tax dispute review

Federal jurisdiction

The IRS Independent Office of Appeals—commonly called Appeals—is an administrative function within the Internal Revenue Service. It is separate from the Examination and Collection functions that make tax determinations and initiate collection actions.

Appeals reviews federal tax disputes. State and local tax assessments use the appeal system of the state, territory, county, city, or other taxing authority that issued the decision.

What Appeals does

Reviews eligible disagreements arising from IRS examinations and proposed tax adjustments.
Handles qualifying collection disputes, including Collection Due Process and Collection Appeals Program matters.
Reviews certain penalty decisions, rejected offers in compromise, innocent-spouse determinations, and other decisions when the governing notice provides appeal rights.
Conducts informal conferences by correspondence, telephone, video, or in person.
Offers mediation and other alternative dispute-resolution programs for qualifying matters.
May work on a docketed U.S. Tax Court case when the taxpayer did not previously have an Appeals opportunity.

What Appeals does not do

It does not conduct the original audit or initiate the original collection action.
It does not process an appeal request sent directly to its headquarters; the IRS office named in the notice must receive and route the request.
It does not replace the U.S. Tax Court, a federal district court, or the U.S. Court of Federal Claims.
It does not provide individualized legal or tax advice.
It is not the Taxpayer Advocate Service and does not accept a case merely because the taxpayer cannot afford to pay.
It cannot resolve arguments based only on moral, religious, political, constitutional, conscientious, or similar objections.

How a case reaches Appeals

Start with the IRS letter that explains the appeal right. Send the protest, form, or hearing request to the person or office shown in that letter. Do not send the initial request directly to Appeals. The originating IRS office reviews the request, attempts to resolve the dispute, and forwards the file when the issues remain unresolved and the case qualifies.

Different disputes use different documents. An audit may use a small case request, Form 12203, or a formal written protest. A Collection Due Process hearing generally uses Form 12153. A rejected offer in compromise and an innocent-spouse case follow their own instructions.

What happens during the conference

An Appeals officer or settlement officer reviews both the taxpayer's position and the IRS compliance file. The conference is informal. The employee may consider the facts, tax law, court decisions, and hazards of litigation in trying to settle the dispute.

You may represent yourself. An attorney, certified public accountant, or enrolled agent authorized to practice before the IRS may represent you. A valid Form 2848 is generally needed when a representative will communicate on your behalf.

New evidence can return to the originating office

Appeals expects the underlying IRS function to have an opportunity to review the evidence supporting the taxpayer's position. If significant new information or a new issue is first provided in Appeals, the Appeals employee may return the case or refer the material to Examination or Collection for comments and further consideration.

Independence and ex parte communications

Appeals' mission is to resolve federal tax controversies without litigation on a basis that is fair and impartial to both the government and the taxpayer. Certain one-sided communications between Appeals and other IRS functions are restricted to protect that independence. This does not prevent necessary administrative communication that follows the applicable rules.

Checking the status of a request

If more than 120 days have passed since an appeal request was filed and Appeals has not contacted you, the IRS directs you to contact the Examination or Collection office that last worked the case. Confirm whether it resolved the issue or forwarded the file.

If the case was forwarded, use the official Appeals status page for the current telephone number and instructions. As reviewed on August 5, 2026, that page lists 855-865-3401 for assigned-case status questions. Do not send an initial protest or sensitive records to that number without instructions from the assigned employee.

IRS Independent Office of Appeals