You have the power as an individual taxpayer to appeal almost any decision made by the IRS. In fact, you can appeal audit findings, penalties and interest, rejected offers-in-compromise, liens, seizures, garnishments and other collection actions.
However, according to the IRS, appeals is not for you if:
- Your only concern is that you cannot afford to pay the amount you owe
- The correspondence you received from the IRS was a bill and there was no mention of Appeals.
So in these two instances, an appeal would be a premature action to take. If you are concerned you cannot afford to pay the tax you owe, there are channels to go through before you would begin the appeal process.