Form 0853c - Penalty Waiver Or Abatement Disallowed/appeals Procedure Explained - Sample Page 7
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statement of facts, schedules, and other statements are, to the
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best of my knowledge and belief, true, correct, and complete."
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If your authorized representative sends us the protest for you, he or
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she may substitute a declaration stating that he or she prepared the
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statement and accompanying documents and whether he or she knows that
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the statement and accompanying documents are true and correct.
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Please address your response to:
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Internal Revenue Service
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Service Center Penalty Appeals Coordinator
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Attn: _________
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_________
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Even though you are requesting consideration by the Appeals Office,
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the Service Center Appeals coordinator will review your additional
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information first, to determine whether the penalty should be removed
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or reduced. If your appeal can't be resolved immediately with the
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additional information, the coordinator will send your written
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statement to the Appeals Office serving your district.
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REPRESENTATION
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An attorney, certified public accountant, or person enrolled to
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practice before the Internal Revenue Service may represent you. To
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have someone represent you, attach a Form 2848, Power of Attorney and
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Declaration of Representative, (or similar written authorization) to
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your written statement.
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Forms, instructions, and Treasury Department Circular No. 230,
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Regulations Governing the Practice of Attorneys, Certified Public
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Accountants, Enrolled Agents, Enrolled Actuaries, and Appraisers
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before the Internal Revenue Service are available from any Internal
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Revenue Service office. They are also available by calling
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1-800-829-3676 and from our website at
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OTHER INFORMATION ABOUT APPEALING
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If taxes are overdue on your account, you will continue to receive
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bills even if you appeal the penalty. If you decide to appeal, you may
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pay the penalty to avoid further interest charges on the penalty
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amount. If you appeal the penalty and the Appeals Officer determines
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that you are not required to pay it, we will adjust your account and
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send you a refund.
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If you don't appeal, you may file a claim for refund after you pay the
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penalty. If you want to take your case to court immediately, you
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should request in writing that your claim for refund be immediately
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rejected. Then you will be issued a notice of disallowance. You have
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two years from the date of the notice of disallowance to bring suit in
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the United States District Court having jurisdiction or in the United
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States Claims Court.
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HOW TO CONTACT US
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If you have any questions, please call ____________
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