On publication 5; published by the Internal Revenue Service shows the process for taxpayers to follow if the taxpayer disagree with an IRS decision.
According to the IRS If you don’t agree with any or all of the IRS findings given you, you may request a meeting or a telephone conference with the supervisor of the person who issued the findings. If you still don’t agree, you may appeal your case to the Appeals Office of IRS.
You may represent yourself at your appeals conference, or you may have an attorney, certified public accountant, or an individual enrolled to practice before the IRS represent you.
If the meeting did not resolve the disagreement, the taxpayer can appeal the case. Appealing the case may require a written letter of protest outlining why the taxpayer doesn’t agree with the IRS findings. Conferences with Appeals Office personnel are held on an informal manner by correspondence, by telephone or at a personal conference.
”However, if you are a nonresident alien, you cannot take your case to a United States District Court.”
If you would like to learn more about your appeal rights please visit