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Taxpayer's Right to Appeal an
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This information is intended as technical information of use to consultants and individuals doing research. The new IRS Hotline for any Appeals tax matter is 1-877-457-5055, whenever you need assistance with an Appeals tax matter.
The 10 Most Important Things To Know
1.	When a taxpayer does not agree with decisions of IRS employees, the taxpayer has the right to an administrative review with the employee's manager.
2.	A taxpayer may appeal a Notice of Federal Tax Lien before or after the IRS files a lien.
3.	A taxpayer may appeal a denied request to withdraw a Notice of Federal Tax Lien filing and denied discharges, subordinated and non-attachments of liens.
4.	A taxpayer may appeal before or after the IRS places a levy on a taxpayers' wages, bank account, or other property
5.	A taxpayer may appeal a seizure of property before or after the IRS makes a seizure. An appeal after the IRS makes a seizure must be appealed to the Collection Manager within 10 business days after the Notice of Seizure is provided to the taxpayer or left at a taxpayer's home or business.
6.	A taxpayer may appeal a termination of an Installment Agreement when notified that the IRS intends to terminate the installment agreement.
7.	A collection action made by telephone can be appealed by telephone. The taxpayer must state the points of disagreement and a solution to the tax problem. If the taxpayer cannot reach an agreement with the IRS employee, the taxpayer must ask to speak to a manager. The manager is required to reply within 24 hours.
8.	If there is disagreement with a decision of a Revenue Officer, a taxpayer must appeal to the Revenue Officer's Collection Manager. If a taxpayer does not resolve a disagreement with the Collection Manager, the taxpayer may request Appeals consideration by completing Form 9423, Collection Appeal Request, and list the Collection actions for which there is disagreement. Taxpayer must also include a solution to resolve the tax problem. Taxpayer's request for an appeal must be received by the Collection office within 2 days of the Manager conference; otherwise, the collection action will resume
9.	When taxpayer appeals his case, the IRS will normally stop the collection action until the appeal is settled, unless the IRS has reason to believe that collection of the amount owed is at risk.
10.	Once the Appeals Officer makes a decision, that decision is binding on both the taxpayer and the IRS. The Appeals Officer has more discretion to settle the dispute than either the Revenue Officer or his Group Manager.

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Brought to you by Alvin S. Brown, Esq., attorney at law, former Supervisory Manager and Tax Attorney-Advisor, Internal Revenue Service, Office of Chief Counsel, Internal Revenue Service.

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