The results of an audit or CP2000 underreporter notice Collection actions such as a levy, federal tax lien, or the IRS denial of your request for an installment agreement or offer in compromise IRS denial of your penalty relief request
Appeals can generally look at the facts, circumstances, IRS procedures, tax law, and other factors in making a final decision for the IRS. The IRS Office of Appeals operates independently from the IRS to reach an agreement between you and the IRS without having to go to court.
Appeals officers (or settlement officers) are generally the most experienced IRS employees. They specialize in the area of tax law or administration involved in the dispute. For example, if you’re contesting audit findings on a corporation, the appeals officer will have a good understanding of corporate tax law.
Remember: IRS decisions aren’t always final. You may have the right to appeal that decision – informally with an IRS manager and formally with IRS appeals.
Source H&R Block