Preparing a Written Protest to the Appeals Office

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

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.

[Alternatively, or additionally, the attorney or accountant may sign the protest using the following language:]

This protest was prepared by the undersigned. The undersigned does (or does not) know personally whether the statements of fact contained in the protest [and any accompanying documents] are true and correct.

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