Appeals Representation

An unfavorable audit result is not the end of the road. It is the beginning of the next phase.

The IRS Independent Office of Appeals was established specifically to resolve tax disputes without litigation. It represents one of the most powerful tools available to taxpayers who disagree with an audit finding. At Blackridge Tax, we are as experienced in the appeals process as we are in audit defense.

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.

The IRS Appeals Process — Step by Step

Step 1 — Protest Letter

The 30-Day Response

Within 30 days of receiving the examination report, you have the right to request a conference. We prepare a comprehensive written protest — a formal document that sets out the facts, the law, and the specific arguments supporting your position. A well-crafted protest can significantly influence the outcome before you ever enter the room.

Step 2 — Appeals Conference

Independent Negotiation

Your case is assigned to an Appeals Officer — an independent employee whose role is to resolve the dispute fairly. We represent you at every conference, presenting your case with precision. Appeals Officers have broad settlement authority, and we know how to negotiate effectively in this environment.

Step 3 — Settlement or Escalation

Final Resolution

The majority of disputes are resolved here. When a settlement is reached, we ensure terms are clearly documented. If the Appeals Office fails to produce a satisfactory resolution, 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.

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.

At Blackridge Tax, our team includes attorneys licensed before the U.S. Tax Court, CPAs, and Enrolled Agents — 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.

You do not have to face this alone. And with Blackridge Tax, you won’t.

Next Steps

Appeal the Audit Finding.

Request an independent review of the IRS’s determination. Protect your rights.