Examination Appeal:
Small Case Request
You prepare a small case request instead of a written protest if the total amount for any one tax period is $25,000 or less. Send a letter requesting Appeals consideration. Indicate the changes you do not agree with and the reason you don’t agree.
For specific guidance in preparing a small case request/protest, refer to Form 12203, Request for Appeals Review.
Formal Written Protest
Prepare a formal written protest for all of the following situations:
- If the total amount for any one tax period is greater than $25,000.
- Employee plan and exempt organization cases without regard to the dollar amount at issue.
- Partnership and S corporation cases without regard to the dollar amount at issue.
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To prepare a formal written request for Appeals you must:
- Include your name, address, social security number, and daytime telephone number.
- Include a statement that you want to appeal the IRS findings to the Appeals office.
- Include
a copy of the letter showing the proposed changes and findings you
don’t agree with (or the date and symbols from the letter).
- Indicate the tax periods or years involved.
- List all the changes you do not agree with and why you don’t agree.
- State the facts supporting your position on any issue that you do not agree with.
- Cite the law or authority, if any, on which you are relying.
- Sign the written protest under the penalties of perjury.
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Please feel free to contact us at your earliest convenience to discuss you case.