The IRS Office of Appeals is independent from examination and collection. Their job is to settle cases. After an audit, you have 30 days from the 30-day letter to file a written protest. Miss that and the IRS issues a Notice of Deficiency, which raises the stakes significantly.
Collection Due Process hearings under IRC Section 6330 are triggered by collection actions. You have 30 days to request a CDP hearing after a Final Notice of Intent to Levy or NFTL filing. This stops all enforcement while the hearing is pending. We handle IRS appeals at every level.