The examination report that just proposed you owe more is exactly that - a proposal. A ladder of review stands above it, results change at every rung, and the only taxpayers who lose the ladder are the ones who miss its deadlines. Climb it in order.
Rung One: The Manager Conference
For factual disputes - documents the examiner discounted, reconstruction they rejected - request a conference with the examiner's group manager. It is fast, free, and resolves a meaningful share of disagreements, particularly where the examiner's position drifted from the manual or the evidence. It also builds the record: positions stated clearly now frame everything above.
Rung Two: The 30-Day Protest to Appeals
The 30-day letter opens the main event: the Independent Office of Appeals, where a settlement officer applies the standard no examiner may use - the hazards of litigation, what a court would likely do with each issue. The protest is where this rung is won: each disputed issue stated, facts documented with exhibits, law cited, the argument framed in litigation-risk terms. A protest that reads like a hazards memo gets settlement treatment - percentages on issues, penalties traded, concessions both directions - and by policy Appeals will not raise new issues, so the climb cannot make things worse on new fronts.
Rung Three: The 90-Day Petition
The Notice of Deficiency opens 90 days to petition the United States Tax Court - the only route to disputing before paying, on the least forgiving deadline in the system: no extensions, the clock running from the notice date. Filing mostly buys a better negotiation - petitioned cases route to Appeals and Chief Counsel under litigation pricing, and the overwhelming majority settle - with the small-case election simplifying procedure for disputes of $50,000 or less per year. Below the ladder sit the post-assessment repairs - audit reconsideration, refund claims - but they are harder climbs than the rungs above. If a report or a letter with a deadline is in your hands, the ladder is open right now. Send it to me before you sign anything.