If you do not agree with the results of an IRS decision on your case, you can appeal your case to a local IRS Appeals Office. An IRS Appeals Office is not connected in any way with your local IRS office, as these two entities are independent of one another. You must timely submit your request for an appeal on you case. You or a person who represents you must be prepared to discuss and argue all disputed issues with the appeal officer. In most cases, if a mutual agreement is not reached at your appeals conference, you can go to Tax Court and have a tax court judge review your case.
A timely written protest is required in most cases which sets forth information to support your position. You must also file a written protest if your case involves employee plan and exempt organization, partnership and S corporations, reconsideration of liens, levies, seizures, or installment agreements.
It is generally recommended that you retain an attorney to represent you in the appeals because of the maximum protection of confidentiality that is only available through an attorney.