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Local Enrolled Agents serving Hawaiʻi families and businesses
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Disagree with an IRS decision?

An appeal is your chance to change the outcome—not repeat the argument.

The IRS Independent Office of Appeals is separate from the examiner or collection employee who made the decision. Kōkua Tax identifies the correct appeal procedure, protects the deadline and presents a supported position designed for an impartial review.

Review my appeal deadlineCall (808) 565-8244 →

Audit · Collection · Penalties · Offers · Local Enrolled Agent representation

Do not mail the protest directly to Appeals.

The IRS instructs taxpayers to send it to the office and address shown on the letter granting appeal rights.

Official IRS instructions →

Choose the correct forum

“I want to appeal” is only the beginning.

Audit findings, collection actions, penalty denials and rejected resolution requests use different forms, deadlines and legal standards. The wrong request can delay the case while the deadline continues running.

Proposed audit changes

Examination appeal

Challenge factual or legal adjustments before assessment through a written protest or small-case request when eligible.

Common source: 30-day letter
Lien or final levy notice

Collection Due Process

Use Form 12153 by the stated deadline to seek an independent hearing and preserve possible Tax Court review.

Common deadline: 30 days
Immediate collection dispute

Collection Appeals Program

CAP may address liens, levies, seizures and installment-agreement rejection or termination. It is fast, but generally offers no Tax Court review.

Form 9423 may apply
Penalty or resolution denial

Specialized appeal

Penalty relief, rejected offers in compromise, trust-fund assessments and other decisions carry their own procedures.

Follow the exact letter
Revenue Officer versus Appeals OfficerCollection takes action. Appeals independently reviews disputed action.

A Revenue Officer is an unarmed civil collection employee. The officer carries official credentials and generally schedules a visit by Letter 725-B or phone; unannounced visits are now limited to rare enforcement circumstances. An Appeals Officer does not perform field collection.

Verify IRS employee roles →

Collection Due Process

A timely CDP request can preserve powerful rights.

CDP hearings apply after specified lien and levy notices. A timely request generally suspends levy action for the periods involved while the hearing is pending and preserves the right to seek Tax Court review of the determination.

IRS CDP preparation guidance →

Issues that may be raised

  • Installment agreements, currently not collectible status or an offer in compromise
  • Whether collection procedures were followed
  • Appropriate spousal defenses
  • Challenges to the underlying liability when the taxpayer had no prior opportunity to dispute it
  • Whether the proposed collection action balances efficient collection with unnecessary intrusiveness
A late request may qualify only for an equivalent hearing, which does not provide the same court-review rights.

The written protest

An appeal needs disputed issues, law, facts and proof.

Appeals is not a second customer-service call. A persuasive protest identifies each disputed item, states the taxpayer’s position, explains the supporting facts and law, and includes the documents needed to evaluate it.

1Correct procedureThe notice, deadline, form and destination must match the case.
2Issues in disputeSeparate each adjustment or collection decision clearly.
3Facts and authorityConnect the records to the tax law—not merely to fairness.
4Proposed resolutionTell Appeals what result is supported and why.

CDP versus CAP

Two collection appeals. Different rights.

Collection Due Process
  • Triggered by specified lien or levy notices
  • Generally requested within 30 days
  • Broader collection-alternative review
  • Possible Tax Court review after determination
  • Collection-statute period may be suspended
Collection Appeals Program
  • Available for many immediate collection disputes
  • Often faster and less formal
  • May apply before or after certain actions
  • No judicial review of the CAP decision
  • Best procedure depends on the exact objective

What Appeals can—and cannot—do

Appeals considers litigation risk. It does not rewrite the law.

Appeals can
  • Independently review the IRS position
  • Evaluate factual and legal hazards
  • Consider eligible collection alternatives
  • Resolve many disputes without court
Appeals cannot
  • Extend a missed statutory deadline
  • Settle based only on sympathy or politics
  • Ignore missing returns or current noncompliance
  • Accept unsupported numbers or claims

Why Kōkua Tax

Your appeal should arrive organized, credible and ready to resolve.

Mainland call centers often treat every dispute like a standard form. Kōkua Tax reviews the underlying account, the procedural record and the practical resolution available to a Hawaiʻi taxpayer or business.

Deadline control

We identify the controlling letter date and preserve the strongest available forum.

Account verification

We confirm what the IRS assessed, collected and coded before choosing the argument.

Professional advocacy

Our Enrolled Agents may represent taxpayers before the IRS and Appeals.

Resolution focus

The goal is not simply to object. It is to reach a supportable result that fixes the problem.

Official IRS sources

Read the rules behind the guidance.

IRS: Appeals—an independent organizationIRS: Preparing a request for AppealsIRS: Appeals forms and publicationsIRS: Right to appeal in an independent forumIRS: Revenue Officer contact and identification

Bring the complete notice

Let’s identify the deadline and strongest appeal route.

Give Kōkua Tax 15 minutes to review what the IRS decided, when the letter was issued and what result you need. We will explain how urgent it is and whether representation makes sense.

Schedule my free 15-minute call(808) 565-8244Free · Confidential · Local Enrolled Agents

General educational information only; not legal or tax advice. Appeal rights, deadlines, collection suspensions and court review depend on the exact notice and procedural history.

IRS NoticesLiens & Levies