IRS audit appeal checklist

1. Identify the case and notice

• Audit or examination letter number recorded.
• Examination report and all schedules collected.
• Tax form and every tax period confirmed.
• Proposed tax and penalties recorded by period.
• Agreement form left unsigned while the changes remain disputed.

2. Protect every deadline

• Appeal-rights deadline copied exactly from the letter.
• Mailing, upload, or fax instructions verified.
• Weekend, holiday, and receipt rules checked in the notice.
• Any Notice of Deficiency deadline calendared separately.
• Proof of timely submission planned before the final day.

3. Complete the examination record

• Every requested record already provided to the examiner when possible.
• Conference with the examiner or supervisor considered.
• Each disputed issue matched to the report line and adjustment amount.
• Facts, records, and legal support organized by issue.
• New evidence identified so it can be reviewed by the originating office before transfer.

4. Choose the request type

• Small Case Request eligibility checked for each tax period.
• Total proposed tax and penalties confirmed as $25,000 or less per period when using the small-case route.
• Employee-plan, exempt-organization, partnership, and S corporation exclusions checked.
• Current Form 12203 downloaded from IRS.gov when appropriate.
• Formal written protest prepared when any period exceeds $25,000 or the case type requires it.

5. Draft the protest

• Clear statement requesting review by the Independent Office of Appeals.
• Name, address, daytime phone, tax periods, and proposed changes included.
• Each disputed issue listed separately with the reason for disagreement.
• Supporting facts and available legal authority included.
• Required penalties-of-perjury declaration copied from the current official instructions.
• Taxpayer or authorized representative signature included.
• Form 2848 attached when a representative will act under a power of attorney.

6. Assemble evidence safely

• Readable copies used instead of originals unless specifically required.
• Documents labeled by issue and tax year.
• Personal identifiers placed only on the official IRS package.
• Complete redacted working copy retained when practical.
• Document index or cover sheet prepared for a large record.

7. Submit to the correct office

• Destination copied from the appeal-rights letter.
• Request not sent directly to Appeals or IRS headquarters.
• Authorized delivery channel confirmed for the case.
• Mailing receipt, certified-mail record, fax confirmation, or upload receipt saved.
• Complete copy of everything submitted retained.

8. Prepare for the conference

• Preferred conference method considered: correspondence, phone, video, or in person.
• Short explanation prepared for each disputed issue.
• Settlement authority and representation arrangements discussed when applicable.
• Questions about new evidence prepared.
• All Appeals requests answered within the assigned timeframe.

9. Review payment and interest choices

• Potential interest exposure estimated with professional help when needed.
• Advance payment or section 6603 deposit considered using official IRS guidance.
• Payment versus deposit designation documented.
• Tax Court and refund-suit routes not confused.
• No court or refund deadline allowed to expire while payment choices are reviewed.

10. Follow the case

• Originating Examination office contacted if more than 120 days pass without an Appeals contact.
• Appeals assignment and official contact information confirmed before sending records directly to Appeals.
• Conference notes and proposed settlement computations reviewed carefully.
• Every closing letter checked for a new deadline or court right.

Official sources

• IRS — Preparing a Request for Appeals
• IRS Publication 3498 — The Examination Process
• IRS Publication 5 — Your Appeal Rights
• IRS Form 12203 — Request for Appeals Review
• IRS — Get the status of an appeal request

Related resources

• Appeal an IRS audit decision
• Payment before an audit appeal
• IRS Independent Office of Appeals
• Audit reconsideration checklist