IRS Independent Office of Appeals
The part of the IRS that resolves disputes without litigation. It is separate from the Collection function whose decision you are disputing.
Full Definition
The IRS Independent Office of Appeals is the body that hears disputes between taxpayers and the IRS's own functions. Its stated purpose: "The IRS Independent Office of Appeals is here to resolve disputes, without litigation, in a way that is fair and impartial to the government and to you."
Independence here means independent of the Collection or Examination function that made the decision — not independent of the IRS. That is worth being precise about, because both readings circulate.
How a conference happens: Publication 1660 states Appeals will contact you to schedule one, and that it may be held by telephone, by correspondence, or, if you qualify, face to face at the Appeals office closest to your home, school or place of business. To qualify for a face-to-face conference the IRS states you must not raise issues it deems frivolous or made solely to delay or impede collection.
It also states what happens to new information: generally, Appeals will ask the Collection function to review, verify and give an opinion on anything new you submit, and will share those comments with you and give you the opportunity to respond.
Where a request comes from matters. The instructions to Form 9423 are blunt about it: "Never forward your request for an Appeals conference directly to Appeals. It must be submitted to the office which took the action."
What to do next
Work out which route you are on first — a Collection Due Process hearing, an equivalent hearing, or a Collection Appeals Program request. They reach the same office by different forms, on different deadlines, and with different consequences at the end.
Sources
- IRS Independent Office of Appeals — Internal Revenue Service, retrieved 2026-08-21
- Publication 1660, Collection Appeal Rights — Internal Revenue Service, retrieved 2026-08-18
Last reviewed 2026-08-21 by Tax Resolution Clarity editorial.
Sourced to primary IRS materials and editorially reviewed. Not reviewed by a tax professional. Not tax advice.
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Where to go next
The IRS publishes the rules this page describes. Your own notice governs your dates.