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Appealing of tax audits

Michigan taxpayers can request an appeal when there are disagreements regarding the result of an audit. The appeal involves filing a written protest. Generally, you will only have 30 days to appeal the determination once receiving a letter from the IRS.

The IRS provides instructions on the filing of the written protest. The protest will need to include personal information, facts of the case, the laws and facts supporting your case, and a listing of your disagreements. However, you will need to stick to the facts as you can face perjury charges over any false statement in the protest.

Small case requests

Small case requests involve audits where additional tax amounts or penalties as result of the audit do not exceed $25,000. In a small audit, you will need to include information on a Form 12203 (Request for Appeals Review) or other form supplied by the IRS.

Large case requests

If you owe more than $25,000, your only option for an appeal is to use Form 12203. Form 12203 allows for you to state the items in the IRS audit you disagree with, and then provide the reasons for why you disagree. Again, you should write a letter of protest and document your claim.

It says right on Form 12203 that you can represent yourself during the appeals process. Still, from our experience that is not a good plan.

Tax issues are extremely complex. That the IRS considers additional taxes and penalties of less than $25,000 a “small case” tells us something about how the IRS thinks. The penalties they issue as a result of an audit are also severe. For this reason, having an attorney on your side who understands the audit process could prove highly beneficial.

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