Appeals Mediation Programs Part IV
IRS Independent Office of Appeals:
Appeals Mediation Programs Part IV
Formal Written Protest
A formal written protest is required if the proposed change to the total amount of tax and penalties for any tax period is more than $25,000 in the letter you received.
The total amount includes the proposed increase or decrease in tax and penalties or claimed refund. If more than one tax period is involved and any tax period exceeds the $25,000 threshold, you must file a formal written protest for all periods involved.
For an offer in compromise, include total unpaid tax, penalties and interest due.
A formal written protest is also required in the following cases:
- Employee plan and exempt organization cases regardless of the dollar amount.
- Partnership and S Corporation cases regardless of the dollar amount.
- In all other cases, unless you qualify for the small case request procedure, or other special appeal procedures, such as requesting Appeals consideration of liens, levies, seizures, or installment agreements. See Publication 1660, Collection Appeal Rights, for more information on special collection appeals procedures.
Next week: Continuation of the Appeal Process – Appeals Mediation Programs – Formal Written Protest (cont)