If you do not agree with an IRS decision, there are many ways to appeal the decision.
COLLECTION APPEALS PROGRAM
When a taxpayer disagrees with the findings of the IRS regarding a Levy, Lien, seizure or the denial or termination of an Installment Agreement, the taxpayer has the right to a hearing, formally known as the Collection Appeals Program. If you choose this method, you cannot go to Tax Court on the Appeals’ decision.
COLLECTION DUE PROCESS HEARING
A Collection Due Process hearing is availble if you’ve received a Notice of Federal Tax Lien or Notice of Intent to Levy and you want to request an alternative collection option that would be more desirable such as an Offer in Compromise, Payment Plan, be declared Currently not Collectible, request Innocent Spouse Relief, or request a withdrawal, discharge or subordination of a lien.
TAXPAYER ASSISTANCE ORDER
This appeal is handled by the IRS’s Taxpayer Advocate Service. While the Taxpayer Advocate Service cannot overturn an appeals officer decision, they can to expedite matters and provide helpful assistance.
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