1020 Publ 4576 (PDF)

Official source: IRS Forms, Instructions & Publications (https://www.irs.gov/pub/irs-pdf/p4576.pdf), retrieved 2026-10-03. U.S. Government work (17 U.S.C. § 105).

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The mission of the Internal Revenue Service Independent Office of Appeals (Appeals) is to resolve federal tax controversies without litigation on a basis which:

Appeals is separate from, and independent of, other functions within the IRS. We make decisions based on our own independent review of the facts and the law.

This publication summarizes the Appeals process for penalty appeal cases. It also discusses several topics related to your appeal, including: your right to retain representation before Appeals, your ability to request further review of our decision if you do not agree, and your options for paying any amounts due. It concludes with some useful resources for you to consider, including our website and contact information for the Taxpayer Advocate Service (TAS).

or documentation you provided, and your position as outlined in your protest.

you the opportunity to provide more information about your case or schedule a conference to discuss your case before we make a determination.

you provide to the IRS’s Compliance function for their review.

case, as well as your reasons for requesting penalty relief.

consider any potential hazards of litigation.

revenue procedures, and revenue rulings.

We will explain the basis for our decision to you.

must be an attorney, a certified public accountant, or an enrolled agent authorized to practice before Appeals. If you choose to be represented, please provide us with a completed copy of Form 2848, Power of Attorney and Declaration of Representative, for each person who is a party to the appeal.

Publication 4134, Low Income Taxpayer Clinic List, to learn about free or low-cost assistance available to low-income taxpayers. In addition, low income taxpayer clinics provide education about taxpayer rights and responsibilities for taxpayers who speak English as a second language.

how long it will take to resolve your case if no unusual circumstances develop.

request further review of the penalties by filing a formal suit with either the United States District Court having jurisdiction or the United States Court of Federal Claims. Note : Most penalties must be paid in full before filing suit.

interest and/or penalties from continuing to accrue. Penalties (up to the maximum allowed by law) and interest will continue to accrue on any unpaid balance due until the date of payment.

issue you a notice showing the amount you owe, including interest, if applicable. You should make arrangements to pay this amount in full as soon as possible. If you are not able to make full payment immediately, your options include:

• Making a partial payment (interest will continue to accrue),

• Entering into an installment agreement (interest will continue to accrue), and

• Making an offer in compromise.

arrangements, please contact the IRS by calling 800-8291040 for individuals and 800-829-4933 for businesses. An IRS Customer Service Representative will assist you.

Process, for more information about payment options.

more information on installment agreements and online payment agreements.

Appeals. At our site, you can also view videos and podcasts of the Appeals process.

877-777-4778 [or TTY/TTD 800–829–4059]. TAS is an independent organization within the IRS that helps taxpayers and protects taxpayers’ rights. TAS can offer you help if your tax problem is causing a financial difficulty, you’ve tried and been unable to resolve your issue with the IRS, or you believe an IRS system, process, or procedure just isn’t working as it should. If you qualify for TAS assistance, which is always free, TAS will do everything possible to help you. To learn more about TAS, visit https://taxpayeradvocate.irs.gov/.

Publication 4576 (Rev. 10-2020) Catalog Number 49395S Department of the Treasury Internal Revenue Service www.irs.gov