How appeals officers evaluate submissions — at a glance

Appeals officers decide cases by building an administrative record that answers three core questions: what happened, what does the law require, and what relief (if any) is reasonable. They are neutral fact-finders who expect submissions to be factual, organized, and supported by evidence and legal authority (IRS Appeals Division: https://www.irs.gov/appeals).

What appeals officers focus on

  • Factual clarity and chronology — A concise, dated timeline of events helps the officer follow your narrative and spot gaps. Include who, what, when, where, and why for each disputed item.
  • Complete documentary support — Bank records, invoices, receipts, signed contracts, returns, prior correspondence with the IRS, and third‑party documents that corroborate your statements.
  • Procedural compliance and timeliness — Evidence you met IRS deadlines (or a credible reason for missing them) and that the appeal is within the office’s jurisdiction.
  • Consistency and credibility — Consistent statements across filings, sworn statements, and documents improve credibility. Explain discrepancies early and with proof.
  • Legal and factual argumentation — Cite statutes, regulations, or case law only where relevant. Explain how the law applies to your facts and attach supporting authority.
  • Reasonableness of requested relief — Propose a clear remedy (adjustment, penalty abatement, installment plan) and show how it was calculated or why it is fair.
  • Scope and relevance — Officers are unimpressed by irrelevant materials. Focus on items that directly bear on the disputed issues.

Practical checklist: what to include in your submission

  1. Cover letter — Short statement of who you are, the years/tax periods at issue, and exactly what you want the officer to do. Use plain language.
  2. Concise statement of facts — One- to two‑page narrative with a dated timeline and issue-by-issue headings.
  3. Key documents, organized by issue — Bates number or tab each document; include copies (not originals). Start with the strongest evidence.
  4. Financial calculations — Clear math, worksheets, and assumptions so the officer can reproduce numbers.
  5. Legal authorities — Any statutes, regs, or precedent citations with brief explanation of relevance.
  6. Correspondence and IRS notices — Include prior IRS notices, audit reports, and any prior position statements.
  7. Identity and representation — Taxpayer name, contact info, and Power of Attorney (Form 2848) if an agent represents you (Form 2848: https://www.irs.gov/forms-pubs/about-form-2848).
  8. Proposed resolution — State the relief requested and a short rationale.
  9. Table of contents and index — Make it fast to find key items; officers handle many cases, and a clear map helps.

(See a step‑by‑step layout in our guide: How to Prepare a Simple Administrative Appeal to the IRS Office of Appeals: https://finhelp.io/glossary/how-to-prepare-a-simple-administrative-appeal-to-the-irs-office-of-appeals/)

How to organize documents for maximum impact

  • Use tabs or electronic bookmarks: group items by issue and label with concise headers.
  • Start with a one‑page executive summary of the strongest evidence and your requested outcome.
  • Include a reconciliation table if numbers in your documents differ (show source & date for each figure).
  • Redact sensitive unrelated data, but keep evidence that verifies identity and transactions.

Real-world example (short)

In practice, I represented a client assessed a penalty for underreported income. We provided a one‑page timeline, bank deposit records matched to invoices, email correspondence showing the payer’s dispute, and a clear recalculation. The appeals officer reversed the penalty after finding the audit relied on incomplete records.

Common mistakes that hurt credibility

  • Submitting voluminous, unindexed records without a statement of relevance.
  • Failing to address the IRS’s specific adjustments or to refute the audit’s methodology.
  • Omitting contemporaneous documents that contradict your later explanation.
  • Relying solely on emotion or hardship without corroborating facts; explain hardship but tie it to documents.

Timing and expectations

Timelines vary by case complexity and office workload. Simple issues can resolve in weeks; more complex cases often take months. If you need immediate collection relief, confirm available collection options with the IRS or consider a Collection Due Process (CDP) review (see Practical Differences Between Collection Appeals and CDP Hearings: https://finhelp.io/glossary/practical-differences-between-collection-appeals-and-cdp-hearings/).

When to hire a tax professional

If the issues involve complex law, large amounts, or competing evidence, a CPA, enrolled agent, or tax attorney can sharpen legal arguments, organize exhibits, and reduce procedural errors. In my 15+ years as a CPA/CFP®, I’ve found professionally prepared administrative records materially improve outcomes.

Authoritative sources

Professional disclaimer

This article is educational and does not constitute legal or tax advice. For advice tailored to your situation, consult a qualified tax professional or attorney.