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Accounting Question

Preparing a Written Protest to the Appeals Office

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Generally, an appeal is initiated by filing a written protest stating the reasons why the taxpayer does not agree with the disputed adjustments. If the total amount of tax exceeds $25,000, a formal protest is required. The outline of a sample formal protest disagreeing with a proposed estate tax adjustment is as follows. See Appendix 22B for a complete sample protest.

RE: Protest by Robert Richards

Social Security Number

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Dear Mr. Richards:

I, Robert Richards, hereby protest the proposed adjustments income tax liability set forth in your 30-day letter dated [date of 30-day letter], and the examination report transmitted therewith. The following information is submitted in support of this protest.

Conference.

Name, address and daytime telephone number of taxpayer.

Itemized schedule of unagreed adjustments.

  • Statement of facts.
  • Statement of law.
  • Summary of position.
  • The Estate wants to appeal the findings to the Estate Tax Attorney and requests a hearing before the Appeals Office.
  • [Name and address of taxpayer]
  • [care of with name and address of attorney or accountant] [Telephone number]
  • Oct 15, 2021

    Reply Refer to:1484-6423

    FYE 201812

    Form 1040

    Return filed April 15, 2020

    Under penalties of perjury, I declare that I examined the facts stated in this protest, including any accompanying documents, and, to the best of my knowledge and belief, they are true, correct, and complete.

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