Almost any collection action taken by the IRS can be appealed including for example:
- Rejection of an Offer in Compromise.
- Rejection of an Installment Agreement.
- Proposed Trust Fund Recovery Penalty.
- Denied request to abate penalties (i.e., late payment, late filing, or deposit penalties).
Back to IRS Appeals Representation FAQ
- When do I know for sure that I'm ready to request Appeals Conference?
- What are the possible disadvantages of filing an Appeal rather than proceeding straight to Tax Court?
- How is a Tax Appeal initiated?
- What types of collection actions can be appealed?
- Should I consider an appeal where the IRS has rejected or terminated my installment agreement?
- How does the appeals process ordinarily conclude?
- How long will it be before I hear from the Appeals office after I file my appeal request or protest?
- What happens if I do not respond to a Notice of Deficiency within the required 90 days?
- What commitments does the IRS Appeals Office make in dealing with taxpayers?
- What are the main advantages of filing an Appeal?
- What must be included in protest of IRS Audit findings to be granted an Appeal and position myself for a favorable outcome?
- Is there any way that my decision to bypass Appeals and go straight to Tax Court could backfire?
- Does the filing of an appeal stop interest and penalties from accruing while the appeal is pending?
- Is help available within the IRS itself if I am experiencing economic harm because of an IRS collection action?
- You are the prevailing party if you meet all the following requirements:
- What can I expect from Appeals?
- What protections are in place to make sure the Appeals Office is truly independent?
- How do you request a CDP or equivalent hearing with the Office of Appeals?
- What commitments does the IRS Appeals Office expect from taxpayers?
- Why should I consider engaging The Tax Law Office of David W. Klasing to help negotiate my Appeal?
- What exactly is the function of the IRS Appeals Office?
- What is the first thing I should do If I do not agree with the results of an audit?
- Why should I consider engaging the Tax Law Office of David W. Klasing to, at a minimum, prepare my Tax Court Petition or my Protest in order to be granted an Appeal?
- If I choose to litigate my tax controversy is it possible to recover my administrative and litigation costs?
- What is the procedure to appeal a collection action instituted by the IRS?
- Why would I not want my original tax preparer to represent me in my appeal (or in my audit)?
- What recourse do I have if I cannot reach an agreement with the IRS Office of Appeals?


