Complete your protest and mail it to the IRS address on the letter that explains your appeal rights. This form is to be used to request an Appeals review upon completion of an examination (audit) if you do not agree with our proposed changes from the audit.Sending an IRS audit reconsideration request? On the Form 9423, check the collection action(s) you disagree with and explain why you disagree. 6.1, First Time Abate (FTA). Taxpayer meets first-time penalty abatement criteria. Rejection letter, identify the specific item(s). Form 8857, Request for Innocent Spouse Relief. List each issue separately using letters or numbers for each item, and briefly state why you disagree with the IRS.