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A client opens a 30 day letter, sees the adjustment number at the bottom, and asks whether to just pay it and move on. Work the proposed changes one by one and the bottom line often shrinks, because the revenue agent never had the documentation in front of them. Form 13683 is the structured way to get those facts and that authority in front of IRS Appeals. It is the Statement of Disputed Issues, Catalog Number 39910F, current revision May 2024, attached when a taxpayer requests Appeals review after an exam closes with proposed changes they do not accept.
Examiners often include a blank copy with 30 day letter packages, and the deadline runs from the date on the letter, not the day you opened the envelope. Each contested issue gets listed separately, with the basis for each explained in its own field. Below I cover when 13683 is the right tool versus Form 12203, and how to structure each disputed issue so Appeals can pick it up without rework.
Key Takeaways
- Form 13683 is the IRS Statement of Disputed Issues. Examiners often include a blank copy with 30 day letter packages when a case is unagreed and heading toward Appeals. The current PDF on IRS.gov shows a revision date of 5-2024 (May 2024).
- Use it to outline what you disagree with and why. The Internal Revenue Manual shows Form 13683 in exam closing and Appeals referral procedures, including small case routes.
- Small case threshold examples show “not more than 25,000 per period.” In those situations, the taxpayer may make a small case request and can use Form 12203 or Form 13683, depending on the letter and program. Always follow the exact letter instructions for your tax type.
- Deadlines are tight. Thirty day responses run from the date on the letter, not the day you opened the envelope. Use the submission method stated in the letter.
- Keep your paper trail. IRM procedures tie Form 13683 to the overall case file and closing steps, so save the form, schedules, citations, and correspondence in your permanent records.
What Form 13683 Is, and Why Firms Use It
Form 13683 is a one page summary the IRS calls the Statement of Disputed Issues. You use it after an examination (audit) is complete to identify the proposed audit changes you disagree with, state the facts, cite the law, and request a resolution (it is not the right vehicle for pre-audit disputes, collection issues, or non-examination matters). Examiners send a blank copy with many unagreed report packages, including 30 day letters, because Appeals needs a concise issue statement to start its work.
Think of it as the cover sheet for your protest story. Your full write up, exhibits, and citations can sit behind it, but this page tells the reader what matters, in what order, and what outcome you seek. The less back and forth you create here, the less partner time gets trapped in review loops.
Where Form 13683 Shows Up In IRS Process
- Included with 30 day letter packages for certain exams, along with the examiner’s report.
- Recognized in Appeals referral tables as an option for small case requests in some programs.
- Used alongside other forms, for example Form 12203 for small case Appeals, or a formal protest for larger or more complex matters. Your letter will say what is acceptable.
Pro tip, read the letter first, then build your packet around it. The letter controls the form you can use, where to send it, and your exact deadline.
Who Should Read This Guide
- Partners, directors, and managers who own delivery for IRS exams and Appeals.
- Controllers and in house finance leaders who support unagreed issues.
- Ops leaders who standardize workpapers, naming, and review flow across engagements.
You will get practical steps, plain language templates, and a workflow your team can follow during busy season without burning out.
When To Use Form 13683 vs Form 12203 vs a Formal Protest
Your path depends on the amount at issue, the program, and what the letter allows.
- Small case route, some programs allow a simplified Appeals request when the total tax and penalties for a period are not more than 25,000. In that lane, the IRS may let you submit either Form 12203 or Form 13683 with your package. Always check the letter’s instructions and program specific thresholds.
- Above small case thresholds or complex issues, plan for a formal written protest with full factual statements, law, and exhibits. Your Form 13683 can still serve as a clean, front page summary for the package.
Quick Comparison
| Item | Form 13683, Statement of Disputed Issues | Form 12203, Request for Appeals Review | Formal Written Protest |
| Typical use | Summarize unagreed issues for Appeals | Small case Appeals request where allowed | Larger, complex, or above threshold cases |
| Who completes | Taxpayer or authorized rep | Taxpayer or authorized rep | Taxpayer or authorized rep |
| Length | 1 page summary, plus your attachments | 1 page request, plus your attachments | Multi page narrative with full citations |
| Trigger | Included with many 30 day letters | Allowed by letter when not more than 25,000 per period | Required by letter when above thresholds |
| Governing source | IRM references in exam closing and Appeals tables | IRM Appeals small case procedures | Publication and IRM protest guidance, per letter |
Figures and routes are controlled by your letter and tax type. Use those instructions over any general rule.
How To Complete Form 13683, Step By Step
Here is a practical flow you can run during busy season without stalling reviews.
- Identify the issues you dispute List each proposed adjustment as a distinct issue. Keep the labels short and specific, for example, “Section 199A wage limitation,” “R&D credit wage base,” or “Worker classification, Q2 2023.” This mirrors how Appeals organizes a case.
- Write a clean statement of facts for each issue Facts first, opinions later. Pull facts from workpapers, bank and payroll records, and client emails. Cite exhibit numbers so your reviewer does not hunt for source pages.
- Cite the law you rely on Reference the Code, regulations, revenue rulings, court cases, and IRM sections where relevant. You do not need a law review article. You do need the exact authority you want Appeals to consider.
- State the taxpayer’s position and requested resolution Say what outcome you seek. Examples, remove the adjustment in full, accept a corrected amount, allow a specific credit, or concede a narrow point while preserving a larger position.
- Attach exhibits with a simple index Use a one page index that lists each exhibit, description, and page count. Label files consistently, for example, “Exhibit B, 1099 detail, 12 pages.”
- Sign and date the form (the form instructions explicitly require both a signature and a date in MM/DD/YYYY format, and an unsigned or undated submission may not be treated as a valid Appeals request) and package it as the letter directs. Include Form 2848 if you represent the taxpayer. Send the packet using the method and address in the letter, and calendar a follow up.
Sample Issue Frame You Can Adapt
- Issue, Q2 2023 worker classification for six field techs.
- Facts, Techs worked scheduled shifts on company property, used company tools, and followed supervisor checklists. Contracts labeled them as contractors, however the company set hours and approved time off. Payroll reports and schedules attached, Exhibits A1 to A4.
- Law, Common law factors, Reg. §31.3121(d)‑1, Rev. Rul. 87‑41, selected cases.
- Position, Based on control factors, the workers were employees. Proposed §3509 rates were applied incorrectly to certain reimbursements that do not constitute wages.
- Requested resolution, Remove adjustments tied to expense reimbursements, allow correction to wage base per attached schedules, Exhibits B1 to B3.
Keep each issue on its own block. Your reviewer, your client, and Appeals will thank you for the clean separation.
Deadlines, Delivery, and Records
- Deadlines, most 30 day letters give you 30 days from the letter date to reply. That date controls, not when you open the mail. Build two calendars, an internal “ready by” date, and an external “mail by” date. The IRM shows Form 13683 traveling with 30 day packages in exam closing steps.
- Delivery, follow your letter’s instructions to the letter. Some units accept secure uploads, others require mail or fax. Appeals routing and small case eligibility are program specific.
- Records, save a PDF of the signed form, proof of mailing or upload, and all exhibits. Store the packet in your firm’s permanent client file with the exam folder.
Attachments Most Firms Include
- Copy of the examiner’s report and schedules
- Your issue statements, one per issue
- Exhibits, labeled and indexed
- Authority pack, the citations you relied on
- Signed Form 2848 or 8821 when required
Firm Workflow, How To Make Form 13683 Review Friendly
You want a repeatable playbook, the kind that holds up in March. Try this light SOP.
- Intake Create a single folder, “Appeals_13683_[Client]_[Tax year]”. Drop the letter, report, and deadlines inside. Assign a preparer, senior, and reviewer.
- Draft Preparer fills the facts and exhibits, then builds the one page issue summary for each item. Keep filenames short, no spaces, use version control.
- First review Senior checks facts, authority, and math. They do not rewrite facts. They request missing proof and move the file to the reviewer with a checklist.
- Reviewer pass Partner or director checks tone, legal footing, and requested resolution. They sign off on the submission method and date.
- Submission and log Admin sends the packet as directed, saves proof, and notes the date in the case log. Calendar a follow up in 10 business days.
Where Accountably Fits, If You Need Capacity
If your team is drowning, structured help can keep quality high without throttling partner time. Accountably integrates trained offshore staff inside your workflow to standardize workpapers, naming, and review flow, so your preparer to senior to reviewer ladder stays intact during Appeals season. Use it when you need predictable turnaround and version control, not resumes. Keep security tight with role based access and your systems. This is capacity without chaos, which is what you need when a 30 day clock is ticking.
Common Mistakes To Avoid
Form 13683 packages get bounced more often for procedural slips than for weak arguments. The pattern is the same every season, and the fixes are mechanical once they live in a checklist.
One Page Checklist, Ready To Use
- Read the 30 day letter, note the due date and permitted form.
- Create the Appeals folder, set internal and external calendar dates.
- Draft Form 13683, one block per issue, facts, law, position, ask.
- Build the exhibit index, label files, and cross reference in the facts.
- Senior review, then reviewer sign off.
- Include Form 2848 or 8821 if you represent the taxpayer.
- Submit by the method and address in the letter, save proof.
- Log the case and set a follow up reminder.
Closing Thought
When you use Form 13683 well, you shorten the road to Appeals and protect partner time. Clear issues, clean facts, tight exhibits, and a direct ask, that is the recipe for fewer revisions and faster decisions. And if your team needs capacity, bring in help that follows your SOPs, works in your systems, and respects your review ladder, so delivery never becomes your ceiling.
Sources and Dates
- IRS Form 13683 PDF, Rev. 5-2024.
- IRM 4.25.10 Case Closing Procedures, shows 30 day package contents including blank Form 13683. Crawled last week.
- IRM 4.24.10 Appeals Referral Procedures, shows small case pathway and references to using Form 13683 or Form 12203 when thresholds are met. Crawled last week.
Reusable Checklists
These are the checklists my team runs on every Form 13683 package. Copy them into your firm SOP, drop them into your tax workflow software as task templates, or print and clip to the folder.
30 day letter intake
- Log the letter date and the response deadline on the firm calendar and the client calendar.
- Confirm the tax form number and period on the letter match the return on file.
- Identify the originating examination office and write the response address on the folder.
- List every proposed adjustment in the letter, one row per issue.
- Pull the audit workpapers and the original return into a single Appeals folder.
- Decide Form 13683 versus Form 12203 based on the letter's instructions.
- Confirm a signed Form 2848 or Form 8821 is on file before the firm responds for the taxpayer.
Issue-by-issue draft of Form 13683
- One disputed issue per entry in 'Issue(s) I disagree with,' in the order the 30 day letter raised them.
- For each issue, paragraph 1 states the facts, paragraph 2 cites the authority, paragraph 3 states the requested outcome.
- Tie each fact to a numbered exhibit (invoice number, bank statement date, contract page).
- No standalone 'I disagree' reasons – every entry has a substantive basis.
- Use the continuation page whenever the narrative exceeds the visible field on page 1.
- Verify taxpayer name, TIN, mailing address, telephone, and best time to call match the most recent return.
- Add the taxpayer's signature and the date in MM/DD/YYYY before the package leaves the office.
Submission and follow up
- Number every sheet using 'Sheet ___ of ___' in the upper right of page 1.
- Run a final senior review pass – facts, law, position, ask – before signature.
- Confirm Form 2848 or Form 8821 is attached if the firm is acting for the taxpayer.
- Send by the method named in the 30 day letter (mail, fax, or secure upload) and keep proof of delivery.
- Log the submission date, method, and tracking number in the case file.
- Set follow up reminders at 30 and 60 days post-submission.
- Calendar the Appeals officer call window once the case transfers.
Keep 13683 Season From Stalling
Form 13683 work does not stall the way a 1040 season stalls. It bleeds capacity slowly. Each 30 day letter brings a hard deadline, but the work that builds a clean Appeals package – rebuilding workpapers, indexing exhibits, drafting facts and law for each disputed issue – sits outside the firm's normal compliance calendar and competes with the next return on the bench. Per IRM 4.24.10 Appeals Referral Procedures, the small case pathway and the standard pathway both require a complete and timely response to the examination letter, and missing the window collapses the option to argue the merits in Appeals.
The fix is not more hours. It is a standard production line for Appeals packages so the judgment work happens at the top of the ladder and the assembly work happens below it.
- Standardize the issue block: 'Issue(s) I disagree with' as a one-line tagline, 'Reason(s) for disagreement' as facts, law, position, ask, in that order.
- Build a reusable exhibit index template, numbered and cross-referenced inside the facts paragraph, never inside the reasons paragraph.
- Run a two-pass review – a senior reviewer for substance (does each reason tie to a controlling authority?) and a final reviewer for compliance (taxpayer name, TIN, tax form number, tax period, signature, MM/DD/YYYY date).
- Track the 30 day clock and the 'Sheet ___ of ___' numbering on a single Appeals workflow board so partial submissions do not slip through.
- Calendar the response method named in each 30 day letter (mail, fax, or secure upload) and the proof-of-delivery save step before the package leaves the office.
When the assembly work runs on a standard line, the partner only spends time on the judgment calls – which issues to fight, which authority to cite, when to settle. That is the production model our tax delivery team runs for firms that want their Appeals work moving without their senior reviewers buried.
FAQs
What is IRS Form 13683 used for?
It is the Statement of Disputed Issues. You use it after an examination (audit) is complete to outline unagreed issues, facts, law, and your requested resolution, often in response to a 30 day letter and as part of an Appeals request (it is not for pre-audit disputes or collection matters). The IRS shows it in exam closing steps and Appeals referral procedures.
Who files Form 13683?
The taxpayer or authorized representative prepares it, following the letter’s instructions. Examiners frequently include a blank copy with the 30 day package.
When can I use Form 13683 instead of Form 12203?
In some small case situations, when the total amount for a period is not more than 25,000, the letter may allow Form 12203 or Form 13683 (note these are distinct forms with different roles - Form 12203 is the 'Request for Appeals Review' while Form 13683 is the 'Statement of Disputed Issues' narrative - not interchangeable substitutes). The letter controls which form is acceptable for your program.
What is the latest revision of Form 13683?
IRS.gov hosts Form 13683 with a displayed revision of 5-2024 (May 2024) at the time of writing, and the file is available as a fillable PDF. Always check the current PDF on IRS.gov before you file.
Do I mail or upload the package?
Follow your letter. Some units accept secure electronic submissions, others require mail or fax. Your letter provides the destination and method.
Do I need a Power of Attorney with Form 13683?
If you are acting for the taxpayer, include a signed Form 2848 or an 8821 if you only need access to information. Keep copies with your packet.