IRS Letter 950: The 30-Day Letter After a Field Audit
IRS Letter 950 is the 30-day letter a Field Examination group issues when an audit ends with proposed changes the taxpayer has not accepted (IRM 4.10.8.12.1). It allows 30 days from the letter’s date to sign the agreement form or ask for an Independent Office of Appeals conference. With no reply, a deficiency case moves toward a notice of deficiency.
We found no “Understanding your Letter 950” page on IRS.gov as of October 25, 2026, so this guide relies on the IRS Appeals letter list, IRS publications, Internal Revenue Manual 4.10.8 and the Code.
Deadline to know: The IRS Appeals letter list says a protest goes in “within 30 days from the date of this letter,” and Publication 556 also measures the 30 days from the letter’s date rather than the day it arrives. IRM 4.10.8.12.8 treats more time as discretionary: a manager may grant an extension, normally for no more than 30 days.
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What IRS Letter 950 is
The Internal Revenue Manual explains that a 30-day letter transmits “the findings of the examination” and gives the taxpayer 30 days to request Appeals consideration. IRM 4.10.8.12.1 assigns Letter 950 to “straight deficiency, or mixed deficiency and overassessment cases in Field Examination.” Office Examination cases use Letter 915 instead.
Variants include Letter 950-B (bankruptcy), Letter 950-F (overassessments and no-change cases with adjustments) and Letter 950-Z (Large Business and International). The IRS Appeals list titles the base letter “30-Day Letter-Straight Deficiency,” says it “may be used for various types of tax,” and also mentions straight overassessments, which the IRM routes to Letter 950-F. For federal, state and local government employers, an IRS Appeals page says Letter 950 is “generally used to propose adjustments to employment taxes.”
Audits conducted by mail end with a different letter: the Taxpayer Advocate Service names Letter 525 for those, covered in the Letter 525 guide. How the examination itself works is explained in the IRS audit guide.
What arrives with the letter
IRM 4.10.8.12.1 requires a complete examination report, a waiver when one applies, and Publication 3498. For individuals and corporations, IRM 4.10.8.12.2 pairs Form 4549-A with Form 870.
| Enclosure | Role, per the IRM |
|---|---|
| Form 4549-A | Report of Income Tax Examination Changes with no line for the taxpayer to sign |
| Form 870 | Waiver used to obtain the taxpayer’s consent to assessment |
| Issue explanations | Field Examination: a lead sheet per issue (conclusion, facts, law, taxpayer’s position); LB&I: Form 886-A |
| Publication 3498 | “must always be enclosed,” even if sent earlier |
The sources differ on the publication. Publication 556 (September 2013) lists “A copy of Publication 5,” while the current IRM names Publication 3498, so the titles printed on the letter are the ones that apply.
Under IRM 4.10.8.12.7, examiners generally deliver 30-day letters in person; a mailed one goes by ordinary mail unless proof of delivery is wanted, and the representative gets a copy.
The ways to answer a Letter 950
- Agree. Publication 556 says to sign and return either the examination report or the waiver form and keep a copy. Under IRM 4.10.8.12.9.2, a signed agreement or full payment closes the case within 10 days of receipt.
- Agree in part. The examiner solicits a partial agreement and, if enough time remains on the statute, issues a new 30-day letter for the issues still in dispute.
- Request Appeals. A small case request or a formal written protest goes to the IRS address in the letter within its time limit (Publication 5). The next section covers which one applies.
- No reply. The case heads toward a notice of deficiency, described further below.
Steps Publication 5 lists before an appeal
Publication 5 asks taxpayers to give the examiner any requested documents first, since new material raised at Appeals “will likely delay” the case, then describes talking with the examiner, the supervisor, and, where eligible, Fast Track Settlement with an Appeals employee acting as a neutral.
The statute of limitations check
IRM 4.10.8.12.1 requires at least 365 days left on the assessment statute when Appeals receives the case (270 days for estate tax). Publication 5 says the IRS will ask the taxpayer to extend the date if needed, and “If you choose not to extend the date, Appeals will not accept your case.” When fewer than 240 days remain, examiners send Letter 5153, which the IRM says “is not a 30-day letter.”
Small case request or formal written protest
Publication 5 and IRM 4.10.8.12.9.3 sort Appeals requests by the amount in dispute per tax period, counting the proposed increase or decrease in tax and penalties, or a claimed refund.
| Amount in the letter | Request Appeals accepts |
|---|---|
| $25,000 or less for each tax period | Small case request: a brief statement of the disputed issues and reasons, or Form 12203 |
| More than $25,000 for any one period | Formal written protest covering every period in the letter |
| Partnership, S corporation, employee plan or exempt organization case | Formal written protest at any amount |
Publication 5 has a formal protest state the wish to appeal and give a name, address and daytime phone; each disputed issue, period, proposed change and reason; supporting facts; and any law relied on, signed under the penalties of perjury declaration it prints. A representative who signs uses one of two alternate declarations.
IRM 4.10.8.12.9.3 calls a request “adequate” only if it holds everything Publication 5 requires; an incomplete one is returned with time to fix it, and a small case request based solely on inability to pay is inadequate. Publication 5 adds that Appeals cannot consider moral, religious, political or constitutional objections.
One wording conflict: the IRS Appeals page for federal, state and local government taxpayers counts “tax, penalties, and interest” toward the $25,000, while Publication 5 and the IRM count tax and penalties.
Preparing a protest for a Letter 950?
An attorney can review the examination report and explain which Appeals requirements apply to the periods in the letter.
If there is no reply: the 90-day letter
Under IRM 4.10.8.12.10, a taxpayer who signaled an intent to protest but missed the date gets Letter 923, a reminder sent no later than seven calendar days after the original 30 days. Otherwise, within 20 days after the protest period ends, a deficiency case is closed to Technical Services “for issuance of a notice of deficiency.”
Publication 3498 calls that notice “a legal document” stating the proposed tax and penalties. Section 6212(a) authorizes sending it by certified or registered mail. Under § 6213(a), the taxpayer has 90 days, or 150 days if addressed outside the United States, to petition the U.S. Tax Court, and the IRS generally cannot assess the deficiency or levy for it until that period ends or a Tax Court decision becomes final. Publication 5 says talks with examiners or Appeals do not extend that period. Without a petition, the IRS sends a bill.
The Taxpayer Advocate Service says the notice of deficiency after an in-person audit is generally Letter 531. A different version of the 90-day letter, sent with Form 5564, is explained in the CP3219A guide.
How an Appeals review works
Section 7803(e) establishes the IRS Independent Office of Appeals “to resolve Federal tax controversies without litigation” on a basis fair and impartial to both sides. Publication 5 calls it separate from the division that proposed the changes and “the only level of administrative appeal within the IRS.”
- Format. IRM 8.6.1.5.1 offers telephone, correspondence, in-person, video and Virtual Service Delivery conferences, and says “Generally, conferences are held by phone.”
- Tone. IRM 8.6.1.5 says conferences are informal “to promote frank discussion and mutual understanding.”
- New evidence. Publication 5 says Appeals generally returns new information or new issues to the originating office, whose comments the taxpayer then sees and can answer.
If Appeals and the taxpayer do not agree, Publication 556 says the 90-day letter follows. Publication 5 lists the U.S. District Court and Court of Federal Claims as options generally only after full payment and a refund claim, and warns that the Tax Court can impose a penalty of up to $25,000 when a case is mainly for delay or a position is frivolous; Publication 556 lists an unreasonable failure to pursue the IRS appeals system as a further trigger.
Paying when the changes are accepted
- With the agreement. Publication 556 says the additional amount can be paid without waiting for a bill, with interest at the applicable rate.
- After the bill. Publication 3498 (Rev. 5-2025) says that when the amount due is less than $100,000 and is paid within 21 calendar days, no more interest or penalties are charged; at $100,000 or more the window is 10 business days.
- Unable to pay in full. Publication 3498 says to pay what is possible and request an installment agreement. As of October 2026, the IRS payment plans page lists a short-term plan of 180 days or less for balances under $100,000 and an online long-term plan for $50,000 or less with all required returns filed. See the installment agreement guide.
- While still disputing. Publication 556 says a deposit or a payment stops interest on the amount sent; deposit treatment is requested in writing. The IRM calls this a “6603 deposit.”
When an attorney matters
Publication 5 lets a taxpayer appear alone at Appeals or appoint someone authorized to practice there, “such as an attorney, certified public accountant, or enrolled agent”; others may attend only as witnesses. A representative acting without the taxpayer needs a power of attorney such as Form 2848, and the IRS Form 2848 page says that person must be eligible to practice before the IRS. The roles differ in a few places:
- Tax Court. The court’s petitioner guide says a representative “must be admitted to practice before the Tax Court”; its practitioner page says a nonattorney may be admitted once the court’s rules are satisfied. Taxpayers may also file and appear on their own.
- Privilege. Section 7525 gives communications with CPAs and enrolled agents attorney-style confidentiality only in noncriminal tax matters.
- Time. IRM 4.10.8.12.8 lists retaining a representative who needs time for a meaningful protest as a reasonable ground for an extension.
- Cost. Publication 5 says a Low Income Taxpayer Clinic may represent eligible taxpayers who cannot afford representation.
The attorney vs CPA vs enrolled agent comparison covers the roles in more depth.
Related guides
Frequently Asked Questions
Is Letter 950 the same as a notice of deficiency?
No. Letter 950 proposes changes and offers an Appeals conference. Publication 556 says the 90-day letter, also known as a notice of deficiency, follows if there is no response or no agreement in Appeals. Publication 5 says the Tax Court generally cannot be petitioned until a notice like that arrives.
Can the 30-day deadline on Letter 950 be extended?
Sometimes. IRM 4.10.8.12.8 says the procedural rules do not provide for an extension, but one may be granted for reasonable circumstances, such as a newly retained representative, illness, or complex issues. Requests go in writing, and extensions normally run no more than 30 days.
Does the $25,000 small case limit include interest?
Publication 5 and IRM 4.10.8.12.9.3 count the proposed tax and penalties, or a claimed refund, for each tax period. The IRS Appeals page for federal, state and local government taxpayers words it as tax, penalties, and interest. The instructions in the letter govern the specific case.
What does signing the waiver form do?
Form 870 waives the restrictions on assessment and collection. IRM 4.10.8.2.2 says signing it stops interest 30 days after the IRS receives it if the assessment and bill are not made within that period. It does not bar the IRS from asserting a further deficiency later.
Talk through a Letter 950 before the 30 days run
A free, confidential evaluation can help sort out the agreement, Appeals and payment routes the rules allow.
Ray Neu
Ray Neu is the publisher of IRSAttorneys.net. A former law enforcement officer with a background in criminal justice and digital publishing, he oversees editorial direction, partnership standards, and compliance review for the site. He is not an attorney and does not provide legal advice; all tax law content is sourced and reviewed against the standards documented on the Editorial Team & Standards page.
Sources
- IRM 4.10.8, Report Writing
- IRM 8.6.1, Appeals conference procedures
- IRS Appeals: letters offering an appeal opportunity
- IRS FSLG: Appeals process
- Taxpayer Advocate Service: Letters 525 and 915
- Publication 5 (Rev. 4-2021)
- Publication 556 (Rev. September 2013)
- Publication 3498 (Rev. 5-2025)
- 26 U.S.C. § 7803
- 26 U.S.C. § 6212
- 26 U.S.C. § 6213
- 26 U.S.C. § 7525
- IRS: About Form 2848
- U.S. Tax Court: guidance for petitioners
- U.S. Tax Court: practitioners
- IRS: Payment plans
- IRS: CP3219A notice
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