You have a right to appeal most IRS decisions. If you decide to request an appeal, be sure to provide all your information to the IRS employee working your case so they can consider it before it is sent to Appeals. Appeals is required by law to be independent, so if you request an appeal, they will review your case impartially and make a decision based on how the law will apply to the facts of your case.
This video explains what to expect if the IRS compliance division is attempting to collect a debt or has proposed a collection action against you, and you request an appeal.