The IRS Office of Appeals conducts hearings when an individual challenges a determination of tax liability or a notice of lien or levy. The Office of Appeals handles two types of hearings. First, the Office handles collection due process (CDP) hearings, as required by 26 U.S.C. (I.R.C.) §§ 6320(b) and 6330(b). CDP hearings focus on the IRSs means for collecting overdue taxes, and happen after a notice of lien or levy. The Office also hears cases under 26 C.F.R. Part 601. In 601 hearings, taxpayers challenge the amount of taxes allegedly owed. Most cases can be appealed to the U.S. Tax Court.
However, before a hearing occurs, the Office of Appeals attempts to resolve the issue in a non-adversarial manner. Appeals Officers are also involved with alternative dispute resolution (ADR) activities at the IRS.
|Level||Name of Office||Sub-Agency/Bureau/Division:||Are administrative appeals permitted from final decisions at this stage?|