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To make a small case request, the instructions in the letter of proposed tax adjustment provide that the taxpayer should send a brief written statement requesting an appeals conference and indicate the changes with which it does not agree with and the reasons it does not agree with them.

The notice of appeal must be filed with the Tax Court within 90 days after the decision is entered, or 120 days if the IRS appeals first. The cost for filing a notice of appeal depends on the Federal Circuit Court to which the appeal is being made but generally costs $600-$605.

You can file a Notice of Appeal. You must wait 90 days for Income Tax matters or 180 days for GST matters after serving your objection to receive a decision from the Minister. If no decision is rendered within that time, you may file a Notice of Appeal at the Tax Court of Canada.

If you lose your case, or lose some issues in your case, you cannot appeal the decision of the Tax Court to one of the U.S. Courts of Appeals. If you win your case, or win some issues in your case, the IRS cannot appeal.

U.S. Suprme Court decisions are binding on the IRS. For opinions issued against the IRS from other courts, the IRS will often issue an announcement on its position. See AODs.

Tax Appeals - How to Prepare a Written Protest Your name and address; The date and symbols from the examination report listing the proposed adjustments; The tax periods or years involved; A statement of the adjustments being protested; A statement of facts stating the taxpayer's position on contested factual issues;