If the time, place, or method that the IRS schedules is not convenient, the taxpayer may request a change, including a change to another IRS district if the taxpayer has moved or business records are there. The audit notification letter tells which records will be needed. Taxpayers may act on their own behalf or have someone represent or accompany them. If the taxpayer is not present, the representative must have proper written authorization. The auditor will explain the reason for any proposed changes.
Most taxpayers agree to the changes and the audits end at that level.
If there is no agreement at the closing conference with the examiner, the IRS notifies the taxpayer of the right to appeal. If the taxpayer does not respond within 30 days, the IRS issues a statutory notice of deficiency, which gives the taxpayer 90 days to file a petition to the Tax Court. The tax does not have to be paid to appeal within the IRS or to the Tax Court. A case may be further appealed to the U.S. Court of Appeals or to the Supreme Court, if those courts accept the case.