IRS appeal preparation (guidance)

For US business owners and LLC founders, understanding IRS appeal preparation is crucial. The IRS Office of Appeals serves as the primary internal route for resolving audit adjustments and collection actions. A formal written protest is generally required, unless small case procedures apply, and must be submitted within the deadline specified in the IRS letter, typically 30 days. Protests must include taxpayer details, a statement of appeal, a copy of the proposed adjustment, tax periods involved, a list of disputed items with reasons, supporting facts, and any relied-upon law or authority. Representation before the IRS Office of Appeals is limited to attorneys, CPAs, and enrolled agents, requiring Form 2848 for Power of Attorney. For Offer in Compromise (OIC) appeals, specific documentation like Form 433-B and supporting financial records are necessary. State tax appeal processes vary significantly, each with its own deadlines, protest requirements, and administrative tribunals, such as California's Office of Tax Appeals or New York's Division of Tax Appeals. Always consult your specific state's Department of Revenue for precise guidance.