Overview

An IRS Appeals Conference gives taxpayers a structured opportunity to challenge IRS findings or collection actions before resorting to litigation. The Office of Appeals exists to provide independent, impartial review of cases and to resolve disputes based on the facts, law, and the “hazards of litigation” (how a judge might decide). Appeals tends to favor negotiated settlements when appropriate, which often saves time and expense compared with going to court (IRS Office of Appeals). [IRS Appeals]

In my practice as a tax advisor, I’ve seen Appeals conferences turn apparent losses into partial or full wins for taxpayers when the record is organized, the issues are narrowed, and the taxpayer understands realistic settlement levers. This article explains what to expect, how to prepare, typical timelines, and practical negotiation tips.

Who handles Appeals and when you can request one

Any taxpayer who disagrees with an IRS proposed adjustment or certain collection actions may ask for an Appeals review. Common situations include audit adjustments, proposed penalties, and collection actions such as liens or levies that trigger Collection Due Process (CDP) or Collection Appeal Rights (CAR) notices. Deadlines vary by notice type, so always check the letter you received for the exact time to request Appeals (often 30 days but not always) (IRS, How to Appeal a Tax Decision). [How to Appeal a Tax Decision]

For more on when to escalate audit disputes, see our guide: When to Escalate an Audit Dispute to the IRS Office of Appeals.

Types of Appeals Conferences

  • Phone conference: The most common format for straightforward issues.
  • In-person meeting: Often used for complex factual disputes or when documents must be reviewed together.
  • Written-only (paper) appeal: Parties exchange briefs and documents in writing without a live meeting.
  • Virtual/teleconference: Increasingly common; check accessibility rules with Appeals.

The format is typically selected based on complexity, taxpayer preference, and Appeals’ scheduling.

Typical steps in the Appeals process

  1. File a timely protest or formal written request (follow the instructions in your IRS notice). Deadlines differ—read the notice carefully.
  2. Appeals assigns an officer who reviews the administrative file and any submission you provide.
  3. The Appeals office schedules the conference (phone, in-person, or written exchange).
  4. During the conference you present facts, documents, legal arguments, and settlement positions.
  5. Appeals considers the record, may request additional information, and evaluates settlement based on the law and hazards of litigation.
  6. Appeals issues a written determination or closing document reflecting the result; if no agreement is reached, you may retain further rights to litigation or other remedies depending on the case type.

For guidance on timelines and steps before Tax Court, see our piece: The Appeals Process: Steps Before Tax Court.

What the Appeals officer does and does not do

  • Independent reviewer: Appeals officers are separate from the IRS exam or collection teams that issued the original determination.
  • Evaluate risks: They weigh the strengths and weaknesses of each side’s legal and factual positions and the hazards of litigation.
  • Negotiate settlement: They can propose and accept compromises that are reasonable given the risks.
  • Not a judge: Appeals officers won’t issue a binding court judgment; their tools are administrative resolution and closing documents.

Appeals discussions focus on resolving disagreements, not re-auditing the taxpayer.

How to prepare (practical checklist)

  • Read the IRS notice and Appeals procedures carefully; note the deadline to request Appeals.
  • Assemble a concise, issue-focused file: key tax returns, receipts, contracts, bank records, and a chronology of events.
  • Prepare a one- to two-page summary letter that: 1) lists each issue, 2) states the taxpayer’s position, and 3) summarizes supporting evidence.
  • Draft a short exhibits index so the Appeals officer can quickly find supporting documents.
  • Prepare a realistic settlement position and a highest-acceptable outcome.
  • Designate a single point of contact (taxpayer or representative) to avoid mixed messages.
  • If you use a representative, complete the proper power-of-attorney (Form 2848) or representative authorization per the notice instructions.

For a focused preparation guide, see: Preparing Effectively for an IRS Appeals Conference.

What to bring and how to present during the conference

  • Bring only relevant evidence; avoid overwhelming the officer with thousands of pages.
  • Use a clear narrative: what happened, why the IRS position is incorrect or overstated, and what you ask Appeals to do.
  • Be factual, concise, and professional. Avoid emotional or accusatory language.
  • If a technical or legal question is likely, bring a short legal memo or citation list.
  • Agree on next steps and timelines before ending the conference (e.g., additional documents to be submitted and a date for a written response).

In my experience, a well-structured 1–2 page executive summary plus 3–6 exhibits will get more attention and lead to quicker resolution than dumping a large unindexed file.

Possible outcomes

  • Full agreement: Appeals accepts the taxpayer’s position.
  • Partial agreement: Adjustments are reduced but not eliminated.
  • No agreement: Appeals upholds the IRS determination; taxpayer retains any further statutory appeal rights (varies by notice type).
  • Deferred decision: Appeals may request more information or study the record before responding.

If you reach an agreement, Appeals will document it in writing and specify whether the agreement is final. If no agreement is reached, be sure to understand your remaining appeal rights and any deadlines.

Common mistakes to avoid

  • Missing the filing deadline on your notice — that forfeits Appeal rights.
  • Turning up unprepared with disorganized records.
  • Treating Appeals as a final court — it’s an opportunity to negotiate based on hazards of litigation.
  • Not narrowing the issues — the more focused the dispute, the easier it is to resolve.
  • Failing to supply requested additional information promptly.

See our list of traps to avoid: Common Mistakes That Hurt Your Case in an IRS Appeals Conference.

Special note on collection appeals (CDP and CAR)

Collection appeals (like CDP hearings) follow different rules—appeals rights, timelines, and potential relief options such as installment agreements or Offer in Compromise differ. If your issue involves a lien, levy, or collection action, ask Appeals early about Collection Due Process or Collection Appeal Rights procedures. See our guide: Understanding the IRS Appeals Process for Collection Actions.

Timelines — what to expect

Timelines vary widely by office, case complexity, and workload. Simple cases may resolve in a few weeks; complex matters can take several months. Appeals generally aims for timely resolution but will request additional time if needed to evaluate facts or legal issues.

Professional tips for negotiating successfully

  • Lead with the strongest, simplest arguments and supporting facts.
  • Quantify uncertainty: show where documentation is missing and why the evidence supports your position.
  • Know your settlement floor (the worst deal you’ll accept) and your ceiling (the best realistic outcome).
  • Keep negotiations focused on law and evidence; use the hazards-of-litigation analysis to justify compromise offers.
  • Be cooperative and responsive — timeliness signals credibility.

Confidentiality and privilege

Appeals encourages frank settlement discussions. Communications during Appeals are treated as settlement negotiations; however, privilege rules can be nuanced. If privilege is a concern, discuss it with your tax professional and reference IRS guidance on Appeals confidentiality (IRS Office of Appeals). [IRS Appeals]

Next steps after the conference

  • If Appeals needs more information, submit it promptly and document the transmission.
  • Review any written determination carefully and consult your advisor about additional appeal or litigation options.
  • If you reach agreement, confirm that all filing or payment terms are clear and get the closing document in writing.

Final thoughts and disclaimer

An IRS Appeals Conference is a powerful chance to resolve a tax dispute without the time and expense of court. In my practice, disciplined preparation, a clear summary of facts, and realistic expectations are the three factors that most often produce favorable results.

This article is educational and not a substitute for personalized tax or legal advice. Rules, deadlines, and procedures change, and outcomes depend on case-specific facts. Consult a qualified tax professional or the IRS Office of Appeals for advice tailored to your situation.

Authoritative sources

(Information current as of 2025.)