IRS Letter 950
Thirty-Day Letter — Proposed Audit Changes
The audit is done — you have 30 days to agree, appeal, or prepare for Tax Court.
Deadline
30 days to respond — agree, appeal, or request a conference
If you don't respond within 30 days, the IRS issues a Notice of Deficiency (Letter 3219). You then have 90 days to petition Tax Court or the assessment becomes final.
Respond promptly to protect your options and avoid escalation.
What IRS Letter 950 Means
Letter 950 — the 30-Day Letter — is issued at the conclusion of an IRS examination to formally communicate the auditor's proposed changes to your return. It includes the Examination Report (Form 4549 or equivalent) detailing each proposed adjustment, the additional tax, and any penalties.
The 30-day window is your opportunity to: (1) agree with the proposed changes and sign the waiver, (2) disagree and request an IRS Office of Appeals conference, or (3) do nothing (which leads to a Notice of Deficiency). Most tax professionals recommend requesting an Appeals conference in almost all cases — Appeals resolves cases favorably far more often than audit-level negotiations.
The Appeals process is independent of the auditor — Appeals officers are not advocates for the IRS position. They are authorized to settle cases based on the 'hazards of litigation' — meaning they can give you credit for a reasonable case even if the auditor wouldn't. Letter 950 is your entry point to this more favorable forum.
What the IRS Can Do If You Don't Respond
- Issue a Notice of Deficiency (Letter 3219) if you don't respond within 30 days
- Assess the proposed deficiency automatically if you miss the 90-day Tax Court deadline
- Begin collection once the assessment is final
What You Should Do Right Now
- 1
Review the Examination Report (enclosed with Letter 950) in detail — understand every proposed change
- 2
Evaluate whether the proposed changes are correct or disputable
- 3
If you disagree with any item, request an Appeals conference by writing to the IRS within 30 days
- 4
Do not sign the agreement form unless you are certain all proposed changes are correct
- 5
Contact a tax professional immediately — the choice between agreeing, appealing, or going to Tax Court is consequential
Resolution Options Available to You
Frequently Asked Questions About IRS Letter 950
Should I appeal or just pay the proposed tax after Letter 950?
If any proposed change is incorrect or disputable, appeal. The IRS Appeals Office resolves the majority of cases in the taxpayer's favor to some degree — full concession by the IRS is common in cases with adequate documentation. The $50–100+ filing fee for a protest letter is almost always worth it.
How do I request an Appeals conference after Letter 950?
Write a formal protest letter to the IRS office that issued Letter 950 within 30 days. For cases over $25,000, the protest must include a statement of facts, the legal authority you rely on, and why each proposed change is wrong. A tax professional prepares this document.
What is the Examination Report that comes with Letter 950?
It's the auditor's formal writeup of every proposed change — the specific item adjusted, the amount, the authority relied upon, and the resulting tax. This becomes the working document for your Appeals conference or Tax Court petition.
Can I negotiate with the examiner after receiving Letter 950?
The examiner's position is typically final by the time Letter 950 is issued. Negotiation at that stage is rare and unlikely to succeed. Appeals is the proper forum for negotiation — with a fresh set of eyes and settlement authority the auditor doesn't have.
Professional References
IRC: IRC §6212 — Notice of Deficiency; IRC §7121 — Closing Agreements; Treas. Reg. §601.106 — Appeals Function
IRM: IRM 8.2.1 — IRS Office of Appeals — General Procedures
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