Note:
Internal Revenue Manual Part 4. Examining Process · 2026-10-03 edition · updated 2026-10-04 · United States
Form 12203 does not have to be submitted with a penalties of perjury statement as is required with a formal written protest to Appeals.
If the total amount of tax plus penalties for any tax period is more $25,000, the taxpayer must submit a formal protest to Appeals.
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