The IRS decided against you.
That is usually not the end of it.
Appeals protests, CDP hearings, collection appeals, innocent spouse relief and audit reconsideration. An Enrolled Agent has unlimited practice rights before IRS Appeals — you do not need a lawyer to be represented there.
Appeals runs on deadlines and almost all of them are short. Thirty days to protest a revenue agent report. Thirty days from a final notice of intent to levy to file Form 12153 and keep collection suspended. Thirty days from the lien filing notice. Ninety days from a statutory notice of deficiency, which is the one deadline that cannot be extended by anybody for any reason. Miss the date and the argument does not get weaker, it usually disappears.
How we fix it.
The deadline first
After the call, upload the letter to your secure TaxDome portal. No office visit. Before anything else we find the date on it and work out what is still open, because that single fact decides whether this is a protest, a Fast Track conference, a CDP hearing, an equivalent hearing or a reconsideration.
The protest drafted
A written protest with the facts, the law and the specific findings we disagree with — or Form 12153, Form 8857 or Form 843, depending on which door is open. Filed inside the window with proof of mailing.
Appeals hears it
The conference is by phone, video or in person and it is with an Appeals officer who was not part of the original decision. We present it. You do not have to attend.
What comes next
A settlement, a sustained determination, or a determination letter that preserves the next step. We tell you plainly where a matter belongs in Tax Court instead, because that is a different forum and we will say so.
Why us for IRS appeals.
Enrolled Agent, enrolled to represent taxpayers before the IRS in all 50 states, alongside CPAs and attorneys.
Finance training: the math behind every recommendation we make.
Appeals without a lawyer — the unlimited practice rights explained.
Circular 230 gives three groups unlimited practice rights before the IRS: attorneys, CPAs and Enrolled Agents. Unlimited means we can represent you in any matter before any IRS office, including Appeals, on any tax type and any year, without a limit on the kind of proceeding. Enrollment as an Enrolled Agent comes from the Treasury and is tax-specific — it is earned by examination on representation, procedure and tax law, or by qualifying IRS service. Appeals is an administrative forum inside the IRS, not a court, and an EA stands in it on the same footing.
CDP, equivalent hearing, CAP and Fast Track are four different doors.
A Collection Due Process hearing is requested on Form 12153 within 30 days of a final notice of intent to levy or the lien filing notice; filing it suspends levy action and preserves the right to take the determination to Tax Court. Miss that window and you can still request an equivalent hearing for up to a year — the Appeals officer looks at the same issues, but collection is not automatically suspended and there is no Tax Court review. The Collection Appeals Program, requested on Form 9423, is faster and covers specific collection actions such as a rejected or terminated installment agreement or a lien filing, but its decision is final and cannot be reviewed by a court. Fast Track Settlement is the fourth door and the earliest one: while the case is still open in Examination, an Appeals officer comes in as a neutral mediator, the case never leaves Exam, and it is measured in weeks rather than months. Fast Track Mediation is the same idea for a collection matter. Both close once the case moves on, which is why the date on your letter decides whether the door is still open. IRS Appeals or a CDP hearing is $2,500.
Innocent spouse, reconsideration and Form 843.
Innocent spouse relief on Form 8857 comes in three shapes: relief from an understatement you did not know about, separation of liability for a former spouse, and equitable relief where neither of the first two fits but holding you liable would be unfair. It is $2,000. Audit reconsideration reopens an examination that closed against you — typically because you never got the letters or never sent the documents — and it is $1,500. Form 843 is the claim for refund and request for abatement used for penalties and certain interest, and a written reasonable-cause abatement is $900.
Pricing, on the page.
Published prices · Quoted in writing before any work startsHow it works: one annual fee, half paid at engagement and half before your return is filed. Everything past the package baseline is a published add-on at a fixed price, so nobody counts forms. Books, payroll and sales tax are the only monthly items, because they are the only monthly work. See the full grid and every add-on or start your intake.
One practitioner. Every file, personally led.
Cody is an Enrolled Agent with an MBA, a solo practitioner with a small support team, working out of Lakeland, Florida.
Every client engagement is led by Cody personally. The firm stays deliberately small so the work stays deliberately careful. The person who filed your return is the person who handles the IRS.
Common questions.
If yours isn't here, ask it on the intake — we read every one before the first call.
How long do I have to request a CDP hearing?
30 days from the date on the final notice of intent to levy — CP90, LT11 or Letter 1058 — or, for a lien, 30 days beginning the day after the fifth business day following the lien filing, which is what Letter 3172 tells you. Form 12153 has to be filed inside that window. Filing it suspends levy action while Appeals considers the case and preserves your right to take the determination to Tax Court.
I missed the 30 days. Is there anything left?
Usually yes. You can request an equivalent hearing for up to one year after the notice. The same Appeals officer considers the same collection alternatives, so practically the conversation is similar — but collection is not automatically suspended and the determination cannot be reviewed by the Tax Court. It is still very much worth filing, and it is the same $2,500.
What is CAP, and when is it better?
The Collection Appeals Program is the fast route, and it is requested on Form 9423, the Collection Appeal Request. It covers specific actions — a lien filed, a levy proposed or taken, an installment agreement rejected, modified or terminated — and it usually gets a conference within days rather than months. The trade-off is that the CAP decision is final and no court reviews it, and you cannot raise the underlying liability there. When a rejected agreement needs fixing this month, CAP is the right door. If the case is still open in Examination rather than Collection, ask about Fast Track Settlement instead — a mediated conference with an Appeals officer before the case ever leaves Exam.
Do I need a lawyer to go to Appeals?
No. Appeals is an administrative function of the IRS, and Enrolled Agents, CPAs and attorneys all hold unlimited practice rights before it under Circular 230. Where a matter genuinely belongs in the United States Tax Court, or where it is criminal rather than civil, that is a different forum and we will tell you so and help you find the right counsel.
What is audit reconsideration for?
For an examination that closed against you when it should not have. The most common cases are a taxpayer who never received the letters because the IRS had an old address, a substitute for return that was assessed without any deductions, or documents that existed but were never submitted. There is no form — it is a written request with the evidence attached — and it is $1,500. It does not work as a second bite at an audit you fully participated in and lost; that is what Appeals is for.
Does innocent spouse relief apply to me?
It applies where a joint return produced a liability from your spouse's income, deductions or credits, and it would be unfair to hold you responsible for it. The three routes cover an understatement you did not know about, separation of liability once you are divorced or separated, and equitable relief for everything else — including, in some cases, a balance that was correctly reported but never paid. Form 8857 generally has to be filed within two years of the first collection activity against you for the understatement routes, which makes the timing worth checking today rather than next year. One thing worth getting right before you file anything: Form 8379, injured spouse, is a different remedy and the most common mix-up in this area. Injured spouse is how you claim back your share of a joint refund that was taken to pay a debt that was only your spouse's — their back child support, their defaulted student loan, their old tax years. Innocent spouse on Form 8857 is relief from the liability itself. If your problem is an offset refund, it is the 8379, and we quote that engagement upfront the same way.
Related
- IRS representationEvery representation fee published, handled by an Enrolled Agent.
- IRS audit representationMail, office and field audits handled, so you don't meet the IRS alone.
- IRS payment plans and collectionsPayment plans, hardship status and levy releases, with the option you qualify for.
- IRS notice responseAny notice number answered for one flat fee of $600.
Tell us the letter and the date on it. The date decides which door is still open.
If your letter says 30 days and it is dated three weeks ago, call rather than fill in the form.
Tell us what you want to appeal.
A few questions, then pick a time for a free 15-minute call with Cody. Nothing starts until you sign an engagement letter.
Prefer to talk? Call (863) 370-8115 or Book a 15-minute call.
Form not loading? Open it in a new tab, or call (863) 370-8115.