Appealing a tax decision could be the best hope you have to get a decision reconsidered short of going to court. A big advantage of Appeals is you get a second look at your issue with someone who is not familiar with your case and situation. They will also be looking at the case with an eye toward getting the case resolved and avoiding possible litigation. If you properly meet all deadlines, you will still usually retain your right to go to court if you are not satisfied with the results of the appeal. We have received excellent results appealing cases within the Internal Revenue Service. If you have any questions or need help, call us at 1-800-408-3122 or email us at

What if the IRS still says I owe taxes, but I don’t believe they are right?

If the Internal Revenue Service sends you a notice or informs you that there are taxes, penalties or interest due from you for one or more tax periods, it is important to know that you still have the right to appeal an unfavorable decision. It is very important for you to act quickly so that you maintain all your appeals rights and options. You also do not have to go through this process by yourself as you can hire a professional to assist you with the appeals process.

Options for appealing an unfavorable decision

If your initial efforts are rejected by the Internal Revenue Service, there are different types of appeals available to you, including the Collection Appeals Program and Collection Due Process. While there are similarities with each of these types types of appeal, there are important differences, and it is very important to timely decide which avenue Is better to take in your situation, and to exactly follow the procedures of each, to ensure you take full advantage of your rights as a taxpayer. More detailed information can be found in our book “Help! I Owe Taxes” which can be downloaded from this site.

Collection Appeals Program

The collection appeals program allows you to explain why you disagree with IRS collection action, and give your ideas to resolve the problem.

Collections Due Process

If you are no longer eligible for the collections appeal program, you still may qualify for this type of hearing. However the decision here cannot be appealed in tax court.

Tax Court

You can go to court to appeal a collections due process decision that the IRS independent office of appeals has made about your disagreement.

Questions You Might Have

The issues to bring up on appeal will vary greatly based upon the particular situation, but you should be prepared to clarify the facts and your position, including gathering all your evidence to support the facts and your position in a straightforward logical form. We have found that presenting evidence in a logical, organized way to IRS personnel is the best way to help them to help you get a result that is acceptable.
You should not appeal an IRS decision simply because you do not have the money to pay the amount owed. In that case you should consider an installment agreement or one of the many other options available from the Internal Revenue Service to arrange a payment agreement.
If the appeals officer upholds the Internal Revenue Service decision, you still have the right to follow the procedures necessary to file a lawsuit against the IRS. It is possible to represent yourself in court if that is what you choose to do.
There is a separate appeals process for taxpayers once their case has reached the collections stage with the IRS?At this stage however, the argument is not the legitimacy of the amount due, but it is about the process the IRS uses for collecting the amounts due. If the IRS obtains a lien against your property, you are immediately entitled to a hearing.
Call us at 1-800-408-3122 or you can email us at for a free, no obligation consultation.

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