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Appeals, the 90-day letter and the courts

SEE 3 Chapter 23 · IRS outline 3D1, 3D2, 3D3, 3D4, 3D5, 2F10

Daniel and the examiner could not agree on the van. Most disputes like his end not in court but at the IRS Independent Office of Appeals, where an Appeals officer weighs the hazards of litigation and looks for a fair settlement. This chapter covers the right to appeal, how to ask, what happens at the conference, how cases settle, the 90-day letter that follows if they don't, and the courts beyond, where an enrolled agent's practice rights mostly end.

In this chapter

1. The right to appeal and the independence of Appeals
2. Asking for Appeals: small case request or formal protest
3. The enrolled agent at the Appeals conference
4. How Appeals settles
5. The 90-day letter
6. Beyond Appeals: the courts, and where EAs stop

This chapter has 6 lessons and 50 practice MCQs with explanations, plus flashcards and a recall sheet.

What this chapter covers

• The right to appeal
• protests and small case requests
• the conference
• settlement
• the notice of deficiency
• Tax Court, district court and the Court of Federal Claims

Chapter 22: Representing a taxpayer in an examination · Chapter 24: Accuracy, records and data security