James D. Lynch
All Taxpayers Have the Right to Appeal an IRS Decision in an Independent Forum
Office of Appeals: The IRS Independent Office of Appeals is an independent organization within the Internal Revenue Service that helps taxpayers resolve their tax disputes through an informal, administrative process. Taxpayers are entitled to a fair and impartial administrative appeal of most IRS decisions, including many penalties. Taxpayers also have the right to receive a written response regarding a decision from the IRS Office of Appeals.
Tax Court: Taxpayers who receive a statutory notice of deficiency (which is an IRS letter proposing additional tax) and who then timely file a petition with the United States Tax Court may dispute the proposed adjustment before having to pay the tax.
Federal Court: Taxpayers who miss the Tax Court deadline or whose claim for a refund is denied by the IRS may file a refund suit in a United States district court or the United States Court of Federal Claims after fully paying the tax.