Appeals Representation
The IRS Appeals Process — Step by Step
When an audit concludes with findings you disagree with, you have the right to appeal. Here is how the process works:
Step 1 — Protest Letter
Within 30 days of receiving the examination report, you have the right to request a conference with the IRS Independent Office of Appeals. At Blackridge Tax, we prepare a comprehensive written protest on your behalf — a formal document that sets out the facts of your case, the applicable law, and the specific arguments supporting your position. A well-crafted protest letter is one of the most important documents in the entire appeals process and can significantly influence the outcome of your case.
Step 2 — Appeals Conference
Once your protest is filed, the IRS assigns your case to an Appeals Officer — an independent IRS employee whose role is to resolve the dispute fairly and without litigation. At Blackridge Tax, we represent you at every Appeals conference, presenting your case with the same precision and preparation we bring to every engagement. Appeals Officers have broad settlement authority — meaning they can resolve disputes that the examining division could not — and we know how to negotiate effectively in this environment.
Step 3 — Settlement or Escalation
The majority of tax disputes are resolved at the Appeals level. When a settlement is reached, we ensure the terms are clearly documented and fully protective of your interests. If the Appeals Office fails to produce a satisfactory resolution — or if the amount in dispute warrants more aggressive action — we are fully prepared to escalate your case to the United States Tax Court or federal district court.
State Tax Appeals
California's state tax authorities — the FTB, EDD, and CDTFA — each have their own independent appeals processes with distinct procedures, timelines, and standards. At Blackridge Tax, we represent clients through every level of state tax appeal, from the initial protest through the California Office of Tax Appeals and beyond. Our experience with California's state tax system means we understand not only the law but the practical realities of how these agencies operate — and how to navigate them effectively on your behalf.
When the Audit Finding is Unfavorable - The Appeals Process
An unfavorable audit result is not the end of the road. It is the beginning of the next phase — and at Blackridge Tax, we are as experienced in the appeals process as we are in audit defense.
The IRS has a formal administrative appeals process that is entirely independent of the examining division. The IRS Independent Office of Appeals was established specifically to resolve tax disputes without litigation — and it represents one of the most powerful tools available to taxpayers who disagree with an audit finding.
At Blackridge Tax, we pursue every available avenue of appeal on behalf of our clients — from the initial protest letter through the Appeals Office conference and beyond. Our approach to appeals is deliberate and strategic. We do not simply resubmit the same arguments that failed at the examination level. We analyze the examining officer's findings, identify the weaknesses in their position, and build a comprehensive written protest that presents your case in the strongest possible terms.
Why Representation Matters From Day One
The single most important decision you will make during an audit is whether to face it alone or with experienced representation. Taxpayers who respond to audits without professional guidance consistently face larger assessments, longer examinations, and higher penalties than those who retain qualified representation from the outset.
At Blackridge Tax, our audit defense and appeals team includes a Board Certified Tax Specialist, attorneys licensed in six states and before the U.S. Tax Court, a CPA, and an Enrolled Agent — professionals who have spent their careers navigating exactly the kind of situation you are facing. We know how auditors think, what they are looking for, and how to present your case in the most favorable light possible — at every stage of the process.
You do not have to face this alone. And with Blackridge Tax, you won't.