Choices when the exam closes
When an examination ends with proposed adjustments, you can usually agree to all of them, agree to some, or disagree. Signing an agreement form generally lets the IRS assess the tax, and although later ways to contest it may exist, they tend to require paying first. Before going to Appeals, you can often ask to speak with the examiner's group manager, which sometimes resolves a narrow disagreement or a misunderstanding about the documents. If that does not work, the letter accompanying the report explains how to request an Appeals conference and sets a period for doing it. If you do nothing, the IRS generally issues a notice of deficiency, which gives you a limited window to petition the Tax Court.
Audits by mail and other variations
Not every audit ends with a face-to-face report. Correspondence audits conducted by mail often close with a letter proposing changes, and the appeal rights are described in that letter rather than explained by an examiner. Some notices that look like audits are actually automated matching notices comparing your return with information reported by employers, banks, or brokers, and they are answered differently. Penalties added during the exam, and the reasons given for them, are part of what can be contested. Collection actions such as a lien or a levy have appeal processes of their own, separate from the dispute over how much tax is owed.
Building the record for the appeal
Bring the examination report, every letter you received, the information document requests and your responses, and the records you gave the examiner. We look at what the examiner relied on and what was never considered, and whether documents that were missing during the audit can now be found. If the period the IRS has to assess tax is close to running out, we discuss how a request to extend it affects your options before anything is signed. We then outline the arguments issue by issue and decide with you whether Appeals, a Tax Court petition, or a partial agreement is the sensible way forward. Interest generally keeps accruing during an appeal, so we also talk about whether a deposit makes sense to limit it.
