Overview
Appeals officers in the IRS Office of Appeals handle disputed audit and collection issues outside of litigation. Their job is not to re-audit but to reach a fair administrative resolution by weighing the taxpayer’s documentation, the IRS examiner’s work papers, and applicable law or policy (IRS Office of Appeals: https://www.irs.gov/about-irs/office-of-appeals).
What appeals officers focus on
- Accuracy and arithmetic: Basic math, totals, and reconciliations must be correct.
- Consistency across records: Tax returns, bank statements, ledgers, and schedules should tell the same story.
- Substantiation: Receipts, invoices, canceled checks, vendor statements, and third‑party records (e.g., Form W‑2, 1099s) that corroborate reported amounts.
- Source documentation vs. summaries: Summaries are useful, but appeals officers expect supporting source documents for key items.
- Timing and plausibility: Dates, frequency, and dollar amounts should fit the taxpayer’s business pattern and industry norms.
- Ability to pay and collection issues: In collection-related appeals, financial statements are evaluated for current and projected ability to pay.
Documents to prepare and submit
- A one-page summary that highlights contested items and your conclusion.
- Reconciled bank statements and trial balance or profit & loss showing how figures tie to the return.
- Receipts, invoices, mileage logs, canceled checks, credit-card statements, and payroll records.
- Third-party documents (1099s, W‑2s, vendor statements) and reconciliations explaining differences.
How officers evaluate adjustments
Appeals officers compare the taxpayer’s records to the IRS examiner’s adjustments. They will:
- Recompute key calculations and test samples when numbers are large or complex.
- Look for corroboration from independent sources (banks, employers, customers).
- Consider the taxpayer’s credibility and the thoroughness of documentation.
- Apply legal standards or Appeals settlement guidelines when closing cases.
Practical tips from practice
In my 15 years working with taxpayers, I’ve found the following materially helps results:
- Lead with a clear summary and reconcile contested numbers to bank or accounting records.
- Label and paginate exhibits; use a table of contents so officers can quickly find supporting docs.
- Provide contemporaneous source documents rather than post‑event reconstructions.
- If numbers are estimates (e.g., cash sales), explain your methodology and show how it compares to historical trends.
- Use a CPA or tax representative for technical disputes—see Using Experts and Professionals Effectively in Tax Appeals for when an expert adds value (https://finhelp.io/glossary/using-experts-and-professionals-effectively-in-tax-appeals/).
Common mistakes to avoid
- Submitting only summaries without source documents.
- Failing to reconcile bank deposits to reported income.
- Presenting late, unorganized packets that make it hard to verify key claims.
Timeline and next steps
Appeals work is fact- and complexity-driven; many cases resolve in months, but complex matters can take a year or longer. Appeals officers may request additional information, propose a conference, or issue a closing memo with settlement recommendations (IRS Appeals information: https://www.irs.gov/about-irs/office-of-appeals).
Related resources
- Preparing for an Appeals Conference: What Evidence Matters Most (https://finhelp.io/glossary/preparing-for-an-appeals-conference-what-evidence-matters-most/)
- How Appeals Officers Review Cases: What to Include in Your Submission (https://finhelp.io/glossary/how-appeals-officers-review-cases-what-to-include-in-your-submission/)
Professional disclaimer
This article is educational and does not replace personalized tax advice. For guidance specific to your case, consult a qualified tax professional or attorney. Official IRS guidance on appeals and recordkeeping can be found at https://www.irs.gov/about-irs/office-of-appeals and https://www.irs.gov/businesses/small-businesses-self-employed/recordkeeping.
Sources
- IRS, Office of Appeals: https://www.irs.gov/about-irs/office-of-appeals
- IRS, Recordkeeping for Individuals and Businesses: https://www.irs.gov/businesses/small-businesses-self-employed/recordkeeping
- GAO and professional practice experience

