IRS notice
IRS Letter 950: Unagreed Audit Results and Your Right to Appeal
The IRS 30-day letter for audit changes you haven't agreed to. File a protest to Appeals within 30 days or expect a notice of deficiency.
Reply by the date on the notice
The IRS says to file your protest within 30 days from the date of the letter; after that, the next step is usually a notice of deficiency with a 90-day Tax Court deadline.
Letter 950 is the IRS 30-day letter used when an examination ends with proposed changes you have not agreed to. It explains your right to appeal to the IRS Independent Office of Appeals and how to file a protest. If you agree, sign the agreement form; if you don't, send a protest to the office that issued the letter, generally within 30 days of the letter date.
What this notice is telling you
- An examination of your return is finished, and the examiner's proposed changes are unagreed.
- The IRS uses this letter for a straight deficiency (more tax), a straight overassessment (less tax), or a mix of both across years or issues.
- The package generally includes the examination report and an agreement form, and explains how to protest.
- It is your formal opportunity to take the dispute to Appeals, an office independent of the examiner, before a notice of deficiency.
What to do
Mark the 30-day date
Count 30 days from the date printed on the letter, not the day it arrived, and work back from there.
Separate the issues
Go through the examination report and list each adjustment you dispute, with the facts and documents behind your position. Appeals considers the issues you put in front of it.
Choose the right kind of request
If the total proposed tax and penalty for each period is $25,000 or less, a small case request (Form 12203 or a short written statement) can be enough. Above that for any period, prepare a formal written protest as described in Publication 5.
Send it to the right place
Mail the protest to the office and address on the letter. The IRS asks that it not go directly to the Independent Office of Appeals.
Decide whether to make a deposit
Interest on any additional tax keeps running during an appeal. A payment or deposit stops interest on the amount sent from the date the IRS receives it.
What makes a Letter 950 different
By the time a Letter 950 arrives, the examination is over and you and the examiner haven't reached agreement. It tells you what the IRS intends to do and gives you a route to have someone outside the exam function review it. The IRS appeal-rights page describes it as the letter used for unagreed straight deficiency, straight overassessment, or mixed deficiency and overassessment cases.
| Small case request | Formal written protest | |
|---|---|---|
| When it applies | Proposed tax and penalty is $25,000 or less for each period | More than $25,000 for any period, and all partnership, S corporation, employee plan and exempt organization cases |
| What it looks like | Form 12203 or a brief statement listing the disputed issues and why you disagree | A structured document covering the issues, facts, law and a signed declaration, per Publication 5 |
| Where it goes | The address on the Letter 950 | The address on the Letter 950 |
If you don't protest or agree
If you don't respond to the 30-day letter, or you go to Appeals and still don't reach agreement, the IRS issues a notice of deficiency, often called the 90-day letter. That notice gives you 90 days (150 if addressed to you outside the United States) to petition the U.S. Tax Court. Those days are fixed by statute, so the 30-day protest is the stage where you still control the timing.
If the letter shows an overassessment
Not every Letter 950 means more tax. Where the examination found you overpaid for a period, the letter covers that too. Read the report for every year listed, because a mixed case can show more tax for one period and less for another.
Where this notice sits
- Letter 950
- CP14
The usual order. Not every account gets every notice, and some steps can be skipped.
Want a CPA to deal with it?
Bring the notice to a free consultation, in person on James Island or by video. We read it with you, tell you what it means for your account and, if you want us to, take over the response once you sign Form 2848.
Tax Controversy — IRS audits, penalty abatement, appeals, and back-tax resolution.
Sources
By Haigler CPA Group. Updated . Notices are revised from time to time, so go by the wording and dates on your own notice. The information on this site is general in nature and is not tax, legal, or accounting advice for your situation. Tax law changes and the right answer depends on facts we would need to review with you. Please speak with a qualified professional before acting on anything you read here.
Questions about Letter 950
Who reviews my protest after a Letter 950?
The IRS Independent Office of Appeals, which is separate from the examiner who proposed the changes. You send the protest to the office and address on the letter, not directly to Appeals.
What does overassessment mean on a Letter 950?
It means the examination concluded your tax for a period should be lower than what was assessed. The IRS uses Letter 950 for deficiency cases, overassessment cases, and cases that mix the two.
Can I still go to Tax Court if I skip Appeals?
If you don't protest, the IRS generally issues a notice of deficiency, and that notice is what opens the 90-day window to petition the Tax Court.
Which publication explains how to write the protest?
Publication 5, Your Appeal Rights and How to Prepare a Protest if You Disagree. The letter itself also lists publications on filing a protest.
Other notices
- Letter 525: General 30-day letter with audit reportThe proposed results of an audit, usually one done by mail, with Form 4549. Respond or request Appeals by the date on the letter.
- CP3219A: Statutory notice of deficiency (income mismatch)The IRS's formal notice of deficiency after an income mismatch. A 90-day Tax Court deadline is running and cannot be extended.
- IRS notice lookupEvery IRS notice carries a code. Find yours below to see what it generally means, which date matters, and what to do before that date passes.
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