Examination Appeals 2026

The examiner won't move. The manager backed the examiner. The 30-day letter is on the table and the client is asking what happens next. Appeals is the next room, and the practitioners who get results there are the ones who understand what Appeals is actually doing — weighing hazards of litigation, not re-running the audit — and write the protest accordingly.

This program walks the examination appeals process from the 30-day letter through the closing agreement. When to appeal versus when to let the SNOD issue and petition Tax Court. What a protest needs to contain, how to frame the disputed issues so an Appeals Officer can work them, and how the dollar threshold changes the form of the request. The conference itself — what to bring, what Appeals can and can't consider, and how ex parte rules shape what gets discussed. And IRM Part 8, which is where Appeals Officers are told how to handle your case; reading it before you write the protest tells you what the AO is required to do, what they're permitted to do, and where the leverage sits.

Who it's for: Experienced EAs, CPAs, and tax attorneys handling representation work, or practitioners adding it to their practice.

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*Self-Study recording not available for NASBA CPE credit.

IRS Program #: 7Q3WU-T-00911-26

CTEC Course #: 6248-CE-00259