Short answer
A small case request asks the IRS Independent Office of Appeals to review audit changes you disagree with when the proposed tax and penalties for each tax period are $25,000 (IRS.gov, 2026) or less. Send a brief signed statement listing each disputed item and why you disagree, or Form 12203, to the address on your 30-day letter by its response date.
Key takeaways
- You can use a small case request instead of a formal written protest when tax and penalties for every period in the report are $25,000 or less (Publication 5).
- If any one period is over the limit, or the case is a partnership or S corporation case, a formal written protest is required.
- List each disputed item and the reason you disagree; disagreeing only because you can’t pay makes the request inadequate.
- Send it to the IRS address on the 30-day letter, not to Appeals, by the response date, generally 30 days from the letter’s date.
- A template is a starting point, not legal advice; it gets an adequate request to Appeals but does not guarantee any change.
When a small case request is allowed
A small case request is the short way to ask for an IRS Appeals review after an audit. Publication 5, Your Appeal Rights and How to Prepare a Protest (Rev. 4-2021), says that if “the total amount of tax and penalties for each tax period involved” is $25,000 (IRS.gov, 2026) or less in the letter you received, you may make a small case request instead of filing a formal written protest. The IRS manual uses the same test and adds that the total includes a proposed increase or decrease in tax, including penalties, or a claimed refund (IRM 4.10.8.12.9.3, revised August 28, 2025).
| Your case | What to send |
|---|---|
| Every tax period in the report is $25,000 or less in tax and penalties | Small case request (this template) or Form 12203 |
| Any one period is over $25,000 | A formal written protest for all periods |
| Partnership or S corporation case, or an employee plan or exempt organization case | A formal written protest at any amount |
| You agree with everything | No appeal; sign the agreement form |
Interest is not part of the Publication 5 test. Publication 3498-A, the mail-audit booklet (Rev. 5-2021), describes the limit as tax, penalties and interest, so if your total is close to the line, ask the examiner which figure applies before you rely on a small case request.
Use it in answer to a 30-day letter, such as a Letter 525, Letter 915 or Letter 950; see the 30-day letter for how they differ. It is not the response to a CP2000, which is an income-matching notice with its own reply form, and it is too late once a notice of deficiency has arrived: from then on the route is the Tax Court, where smaller disputes can use the small case procedure.
Your reasons must be based on the tax law. Publication 5 says Appeals cannot consider arguments based only on “moral, religious, political, constitutional, conscientious, or similar objections.” A request based “solely on the inability to pay” is inadequate under the IRS manual; for that, see options when you can’t pay an audit bill.
A letter or Form 12203?
Publication 5 gives you a choice. You may either “prepare a brief written statement listing the disputed issues and why you disagree,” or complete the appeal request form that came with your letter, or Form 12203, Request for Appeals Review. All three are accepted.
| Option | Best for | Notes |
|---|---|---|
| Appeal request form enclosed with your letter | Most mail audits | Already matched to your case; follow its instructions |
| Form 12203 (Rev. 8-2022) | One or two simple disputed items | One page with spaces for each disputed item and your reason; the form says you can add more pages |
| A letter (this template) | Several items, a penalty dispute, or reasons that need a few sentences each | Lets you tie each reason to an exhibit |
Whatever you choose, give the same information Form 12203 asks for: taxpayer name(s) and identification number(s), mailing address, tax form number, tax period(s), phone number and best time to call, each disputed item with the reason you disagree, and your signature and date. If a representative signs, Form 12203 says to attach a copy of the completed Form 2848.
Publication 5 lists a penalties-of-perjury statement as a requirement for a formal written protest, not for a small case request. If your case needs the full protest, use the formal protest template.
Before you send it: four checks
- Give the examiner everything first. Publication 3498 says that if you raise new information in Appeals, Appeals will generally return the case to the examining office to consider it, which slows things down. Send any missing records to the examiner before or with your request, and use the audit response cover letter to list them.
- Talk to the examiner or a manager. Form 12203 says you may first discuss the findings with the person named on the letter, or their supervisor. A missing document can sometimes be fixed without an appeal.
- Sort agreed from disputed items. You don’t have to appeal everything. Items you accept can be agreed; see whether to agree or appeal.
- Check the assessment statute. Publication 3498 says there generally must be at least 365 days left on the assessment statute when Appeals receives your case; if more time is needed, the IRS will ask you to extend it, and if you don’t, “Appeals will not consider your case.” That request usually comes on Form 872.
Where and how to send it
Send it to the IRS office that sent your 30-day letter, not to Appeals. Publication 5 says to send your request “to the IRS address in the letter you received within the time limit specified in the letter,” and Form 12203 says to return it to the address in the heading of the IRS letter. The examining office then forwards your case to Appeals. Publication 3498 describes the time limit as “generally 30 days from the date of the letter.”
- Include a copy of the 30-day letter and report. It identifies the case and the adjustments you are disputing.
- Keep proof. The IRS audits page says to “always request confirmation that the IRS has received your response” from any delivery service you use.
- Need more time? Call the number on the letter before the response date and follow up in writing. The IRS manual treats extensions as discretionary; see asking for more time on a 30-day letter.
- Joint return. Both spouses should sign. The IRS manual says the signature of only one spouse on a joint-return request does not make it incomplete, but two signatures avoid any question.
This template is a starting point, not legal advice. Filing it gets your case to Appeals if it is adequate; it does not guarantee any change to the result.
The template
Fill in everything in [square brackets], list each disputed item from the report on its own line, and delete what doesn’t apply. A page or two is usually enough.
[Your full name]
[Spouse’s full name, if a joint return]
[Street address]
[City, State ZIP code]
[Daytime phone number and best time to call]
[Date you send the letter]
Internal Revenue Service
[Office, examiner’s name or ID number from the heading of the 30-day letter]
[IRS address exactly as shown on the 30-day letter]
Re: Small case request for Appeals review of [Letter 525 / Letter 915 / Letter 950] dated [date printed on the letter]
Taxpayer name(s): [Name(s) exactly as shown on the letter]
Taxpayer identification number: [SSN, ITIN or EIN as shown on the letter]
Tax form: [Form 1040 or other form examined]
Tax period(s): [tax year(s) in the examination report]
Dear [Examiner’s name, or Sir or Madam]:
I do not agree with some or all of the changes proposed in the examination report sent with your letter dated [date]. I request a conference with the IRS Independent Office of Appeals. The proposed change in tax and penalties for each tax period is within the limit for a small case request, so I am making a small case request rather than filing a formal written protest.
The items I disagree with, and why:
- [Item as described in the report, for example “Disallowed car and truck expenses, Schedule C, line 9”], tax year [year]. I disagree because [one to three sentences of facts: what the expense was, why it qualifies, and which records support it]. [The supporting records were sent to the examiner on [date] as Exhibit [number]. / Copies are enclosed as Exhibit [number].]
- [Item], tax year [year]. I disagree because [reason based on the facts and the tax rules].
- [Penalty, if you dispute it, for example “Accuracy-related penalty”], tax year [year]. I disagree because [reason, for example the facts showing you acted with reasonable cause and in good faith].
[Optional: I agree with the following items and will [sign a partial agreement / pay] for them: [list].]
Please forward this request to the Independent Office of Appeals. I can be reached at [phone number] [best time to call][, and my authorized representative, [representative’s name], can be reached at [phone number]; a copy of the completed Form 2848 is enclosed].
Sincerely,
[Signature] [Date]
[Printed name]
[Spouse’s signature and date, if a joint return]
[Spouse’s printed name]
Enclosures: copy of the 30-day letter and examination report; [exhibits, if any]; [Form 2848, if a representative signs or will speak for you]
A filled-in example
Example (assumed facts). Sam and Lee Park get a Letter 525 dated October 1, 2026 with a report for tax year 2023. The examiner disallowed $6,400 of charitable gifts and $3,100 of unreimbursed medical costs, and added a penalty. The total proposed change in tax and penalties for 2023 is $2,850, well within the small case limit. They had already sent the examiner the charity’s written acknowledgment, but the report says it arrived after the report was prepared. Their disputed-items list reads:
- Charitable contributions, Schedule A, tax year 2023. We disagree. The church’s written acknowledgment dated January 20, 2024, listing each gift, was faxed to the examiner on September 25, 2026 (copy enclosed as Exhibit 1).
- Medical expenses, Schedule A, tax year 2023. We agree with this change.
- Accuracy-related penalty, tax year 2023. We disagree. The underpayment is due to the charitable item, which was correctly reported.
Both sign and date the letter, enclose a copy of the Letter 525 and the report, and mail it to the address on the letter with delivery confirmation before the response date. Figures and facts are assumed for illustration only.
What happens after you send it
The IRS manual tells examiners to review a small case request for completeness. If it is missing information Publication 5 requires, it should be returned to you with additional time to fix it (IRM 4.10.8.12.9.3). Once it is complete, the case goes to Appeals, which Publication 3498 says will contact you or your representative to arrange a conference by phone, video or in person. For mail audits, Publication 3498-A says Appeals usually holds the conference by phone or correspondence.
Interest keeps running while you appeal. Publication 3498-A says interest accrues on unpaid balances until the disagreement is resolved, and that a deposit or an advance payment of the proposed amount stops it. If Appeals and you do not settle, Form 12203 says Appeals will send a notice of deficiency, and you can then take the case to the Tax Court before paying.
Many people file a small case request on their own; Form 12203 is one page. Help is worth considering when the dispute turns on the law rather than a missing receipt, several years are involved, or the IRS asks you to extend the statute. Low Income Taxpayer Clinics can represent eligible taxpayers in Appeals for free or a small fee, and the Taxpayer Advocate Service (877-777-4778 (IRS.gov, 2026)) helps when an IRS problem causes hardship. Global Gate Tax Relief’s team includes licensed tax attorneys, enrolled agents and CPAs. It offers a free consultation, quotes a flat fee upfront if it takes the case, and makes no promise about the result. Request a free review of your 30-day letter or call 1-877-800-8180.
Frequently asked questions
It is a short written request for an IRS Appeals conference after an audit, used when the proposed change in tax and penalties for each tax period is $25,000 or less. You list the items you disagree with and why, in a brief statement or on Form 12203, instead of filing a formal written protest.
Form 12203, Request for Appeals Review, is one way to make a small case request. Publication 5 also accepts a brief written statement listing the disputed issues and why you disagree, or the appeal form that came with your letter.
The response date on your 30-day letter, generally 30 days from the letter’s date according to Publication 3498. If you need more time, call the number on the letter before that date and confirm any extension in writing.
Publication 5 lists a penalties-of-perjury statement as a requirement for a formal written protest. It does not list one for a small case request, which only needs a brief statement of the disputed issues and why you disagree.
The IRS manual says a request missing information required by Publication 5 should be returned to you with additional time to complete it. Fix what is missing and send it back by the new date.
Not through a small case request. The IRS manual treats a request based only on inability to pay as inadequate. Appeals reviews whether the tax is correct; payment options such as a payment plan are a separate step after the tax is assessed.
Sources
- IRS Publication 5, Your Appeal Rights and How to Prepare a Protest if You Disagree (Rev. 4-2021)
- IRS Publication 3498, The Examination Process (Rev. 5-2025)
- IRS Publication 3498-A, The Examination Process (Audits by Mail) (Rev. 5-2021)
- IRS Form 12203, Request for Appeals Review (Rev. 8-2022)
- IRM 4.10.8, Report Writing (4.10.8.12.9.3, Request for Appeals Conference, 08-28-2025)
- IRS: IRS audits (reviewed 17 Feb 2026)
- IRS: Low Income Taxpayer Clinics
We check every figure against IRS.gov and log changes on the key figures page.
Want a professional to look at your audit?
Free consultation, no obligation. If we take your case, the flat fee is quoted upfront before any work begins. If you can handle it yourself through IRS.gov, we will tell you. No outcome is guaranteed.
This page is general information about IRS rules, not tax or legal advice for your situation. IRS figures change; each one links to its official source and the date we last checked it.