The IRS attempts to resolve tax disputes through an administrative appeals system. Taxpayers who, after audit of their tax returns, disagree with a proposed change in their tax liabilities are entitled to an independent review of their cases. Taxpayers are able to seek an immediate, informal appeal with the Appeals Office. Alternatively, the taxpayer can wait for the examiner's report and then request consideration by the Appeals Office and file a protest if necessary.
Taxpayers can forego their right to the above process and await receipt of a deficiency notice.
If the claim is not allowed, a suit for refund may be brought either in the District Court or the Claims Court within a specified period.