The protest window
A written protest within 30 days preserves Appeals rights. For disputed amounts over $25,000, the protest requires specific content: facts, law, and position statement. Under $25,000 can use a simpler small-case request.
Why Appeals matters
Appeals is independent of the examination team. They consider hazards of litigation and can settle for less than the examiner's proposed amount. Most audit disputes resolve at Appeals rather than Tax Court.
Have a specific situation?
Call the office and a human answers.
Common questions
- What if I agree with part of the audit?
- Sign the agreed portion and protest the rest. Partial agreement is standard.
Related
IRS Audit Representation
Herman Viglione, EA, represents taxpayers in IRS and state audits. Correspondence, office, and field audits handled remotely for clients in any state.
Responding to an IRS Notice of Deficiency
The Notice of Deficiency (90-day letter) is your window to petition Tax Court without paying first. Pay, petition within 90 days, or the tax becomes final.