IRS Appeals and Reconsideration: How the Process Works
If you disagree with the results of an IRS audit or a proposed tax assessment, you may have the right to challenge it. The IRS Office of Appeals is an independent branch designed to resolve tax disputes without going to court.
At Bowman Law Firm, we help taxpayers throughout Huntsville and Madison County navigate appeals, audit reconsiderations, and collection hearings.
1. When You Should Appeal an IRS Decision
You may benefit from an appeal if:
The IRS disallowed deductions or credits you believe are valid
An audit resulted in additional tax you disagree with
The IRS denied penalty relief
The IRS proposed a lien, levy, or seizure
The IRS rejected an installment agreement or OIC.
2. Types of IRS Appeals
Appeal After an Audit (30-Day Letter or Notice of Deficiency)
If you disagree with audit findings, you can file a formal written protest outlining:
Issues in dispute
Legal authority
Supporting documentation.
Collection Due Process (CDP) Hearings
If the IRS intends to levy, garnish wages, or file a lien, you may be entitled to a hearing that can temporarily stop enforcement.
Equivalent Hearings
Similar to a CDP hearing, but without the automatic freeze on enforcement.
Penalty Abatement Appeals
Useful for taxpayers seeking:
First-time abatement
Reasonable cause relief (illness, disaster, reliance on incorrect advice).
3. What is Audit Reconsideration?
If you missed deadlines or did not have all the necessary documents during your audit, you may be able to request audit reconsideration.
We use this when:
You didn’t receive the audit notice
You disagreed with the audit but didn’t appeal in time
You now have new documentation.
This can reopen an old audit and potentially reduce or eliminate the assessment.
4. What to Expect During the Appeals Process
In most cases:
Appeals officers review your documentation
The process is less formal than Tax Court
Dispute may settle without litigation
Representation by an attorney–CPA significantly improves outcomes.
5. Don’t Miss Critical Deadlines
Deadlines for appeals are strict:
30 days after a proposed adjustment
90 days after a Notice of Deficiency (Tax Court petition deadline)
30 days for a CDP hearing request
Missing a deadline can limit your options.
Get Help with IRS Appeals in Huntsville
If you received an IRS decision you disagree with, we can review the case and guide you through the appeals or reconsideration process.
Serving Huntsville, Madison, Decatur, Athens, Hazel Green, and all of North Alabama.
📞 (256) 539-9850
🌐 www.bowmanlawfirm.net
