The message from CP12 is definitely, “we don’t want to hear from you.” I mailed my client’s protest to the Austin Service Center, which was the address on the top left corner. That was in August 2021. In April she received a Letter 2644C from the Kansas City Service Center, “Stop 6525,” which said they are still working on it. Then on May 30, she received a CP21B from the Fresno Service Center, saying that there had been a “decrease in tax” of $2,345 and she would get a refund soon. She did, which included a year’s worth of interest.

I’m not sure why there would be a decrease in tax because it would have been illegal for them to assess tax once the protest was filed.

The CP12 says “if you don’t agree with the changes,” call an 800 number “to review your account with a representative.” As we all know, good luck with that. It also says, “if you contact us in writing within 60 days of the date of this notice, we’ll reverse the change we made to your account. You don’t need to provide an explanation or additional documents when you request the reversal, but we’ll consider any information you provide us. However, if you don’t provide us any additional information that justifies the reversal and we believe the reversal is in error, we may forward your case for audit. After we forward your case, the audit staff will contact you within 5 to 6 weeks to fully explain the audit process and your rights, and you may need to provide an explanation or additional documents. After the audit, you’ll have formal appeal rights, including the right to appeal our decision to the United States Tax Court.”

When IRS says “5 to 6 weeks,” what they mean is “nine months.” We had considered filing a Tax Court petition, alleging that the Notice of Deficiency must have been lost in the mail because surely they can’t wait forever when a reversal is requested. That would have elevated the situation to someone above GS-4, and when the case was dismissed it could have been evidence for the next time Congress pretends to enact a Taxpayer Bill of Rights.