Receiving a letter from the IRS stating that your tax case has been denied or adjusted can be intimidating—but it’s not the end of the road. The IRS appeals process gives taxpayers in California the opportunity to challenge IRS decisions and seek fair resolutions.
If you’re preparing for an IRS appeal hearing in Daly City, Alameda, San Francisco, or San Mateo County, it’s essential to understand what happens during an appeal, how to prepare your documentation, and when to seek professional help. At Izella Tax Relief, we’ve guided countless Bay Area taxpayers through successful appeals—protecting their rights and negotiating better outcomes.
What Is an IRS Appeal Hearing?

An IRS appeal hearing allows you to dispute IRS findings without going to court. It’s handled by the IRS Office of Appeals, an independent branch of the IRS designed to resolve disagreements fairly and efficiently.
Common reasons for appeals include:
- Disagreements with audit findings
- Denied deductions or credits
- Rejected Offer in Compromise or installment plan
- Disputed penalties or interest
- Tax lien or levy actions
The goal of an appeal is to reach a settlement that’s acceptable to both you and the IRS without litigation.
When Can You File an Appeal?
You can file an appeal after receiving one of the following IRS letters:
- Notice of Deficiency (CP3219A) – IRS claims you owe additional taxes
- Final Notice of Intent to Levy
- Rejection of Offer in Compromise
- Disallowed Deduction Notice
- Audit Determination Letter
Typically, you have 30 days from the date on the IRS notice to submit a written protest or appeal request. Missing this deadline may result in losing your appeal rights—so timing is crucial.
Step-by-Step Guide: How to Prepare for Your IRS Appeal Hearing

1. Review the IRS Notice Carefully
Identify exactly what the IRS disagrees with. Is it income misreporting? Unverified deductions? Unpaid penalties? Highlight every adjustment and the IRS explanation for it.
Having a tax professional from Izella Tax Relief review the notice ensures nothing is overlooked and that your protest addresses each issue specifically.
2. Gather and Organize Supporting Documents
Documentation is your strongest defense. Collect:
- Income records (W-2s, 1099s, business receipts)
- Bank statements
- Proof of deductions (charitable donations, mileage logs, receipts)
- Prior correspondence with the IRS
Your records must be complete and easy to follow. Appeals officers appreciate clear, concise evidence that supports your claim.
3. Write a Clear and Persuasive Protest Letter
If the amount in dispute exceeds $25,000, you must submit a formal written protest that includes:
- Your name, address, and SSN
- A statement that you’re appealing the IRS decision
- A copy of the letter you received
- A detailed list of each disputed item and why you disagree
- Facts, laws, or IRS code sections supporting your position
- Your signature under penalties of perjury
For smaller disputes (under $25,000), you can file a simplified small case request, which still requires an explanation but less formal structure.
4. Know What Happens During the Hearing
Most IRS appeal hearings are conducted by phone or video conference, although in-person meetings are possible at IRS offices in San Francisco or Oakland.
During the hearing, the Appeals Officer will review your protest and supporting documents. They’ll discuss potential settlements and evaluate whether the IRS’s position can be reasonably challenged.
This is your opportunity to:
- Clarify misunderstandings
- Present additional evidence
- Negotiate payment or penalty relief
Having a professional representative, like Izella Tax Relief, ensures you speak the IRS’s language—accurate, documented, and strategic.
5. Be Honest, Calm, and Professional
The appeal process is not a courtroom. It’s a negotiation. Be factual and avoid emotional arguments. If the IRS made a calculation or procedural error, your representative can point it out respectfully and back it up with documentation.
6. Explore Settlement Options
Appeals are often resolved through compromise. Depending on your situation, options may include:
- Partial settlements on disputed items
- Penalty abatement for reasonable cause
- Amended returns if errors are identified
- Offer in Compromise to settle for less
- Payment plans if you owe balance
A seasoned tax relief specialist knows how to propose realistic solutions the IRS is likely to accept.
7. After the Decision: What’s Next?
If you and the IRS Appeals Office reach an agreement, you’ll sign a Form 870-AD (Offer to Waive Restrictions on Assessment) to finalize it.
If no agreement is reached, you still have the right to take your case to U.S. Tax Court. However, most disputes are settled before reaching that point—especially when you’re represented by a professional familiar with California tax and IRS appeal procedures.
How Izella Tax Relief Helps California Taxpayers

At Izella Tax Relief, we’ve helped Bay Area residents from Daly City, Alameda, San Francisco, and San Mateo County prepare winning appeal strategies for IRS and state tax disputes.
Here’s what we do for you:
✅ Comprehensive Case Review – We analyze every IRS notice and your tax history.
✅ Evidence Preparation – We gather supporting documents and build your defense.
✅ Appeal Representation – We handle communication with IRS Appeals Officers directly.
✅ Negotiation & Settlement – We seek to reduce or eliminate penalties and find the best resolution possible.
✅ Ongoing Compliance Support – We help you stay on track after your case is resolved.
Our goal is to protect your rights, minimize financial impact, and give you peace of mind knowing your appeal is handled by experts who care.
Serving Daly City, Alameda, San Mateo & San Francisco
Izella Tax Relief proudly serves California taxpayers throughout the Bay Area, offering trusted IRS representation and state tax resolution services. Whether you’re facing an IRS appeal, wage garnishment, or audit, you don’t have to face it alone.
📍 Locations Served: Daly City, San Mateo County, Alameda County, and San Francisco, California
Conclusion
Preparing for an IRS appeal hearing requires organization, strategy, and knowledge of how the IRS operates. With the right documentation and professional help, many taxpayers achieve favorable outcomes—sometimes reducing or removing thousands in penalties.
If you’ve received a notice of IRS determination or rejection, don’t wait until it’s too late to act.
Let Izella Tax Relief help you through the appeal process with confidence.
📞 Call (415) 818-6899 or schedule your consultation today.


