The IRS Independent Office of Appeals, sometimes referred to as Appeals, is a separate organization within the IRS. Their mission is to resolve tax disputes fairly and impartially. They are 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 they think law applies to your case. Using this approach, they will resolve most of the cases that come to Appeals. If you decide to request an appeal, be sure to provide all of your information to the IRS employee working your case so that they can consider it before it is sent to Appeals.
Watch this video to learn what to expect if you appeal your case.