Appeals is the administrative appeals office for the IRS. The Appeals Office is separate from – and independent of – the IRS Office taking the action you disagree with. The Appeals Office is the only level of administrative appeal within the IRS.
The Appeals Office attempts to work with taxpayer’s informally to try to settle tax disputes between the taxpayer and the Internal Revenue Service in an effort to avoid a formal court hearing. They consider positions taken by both the taxpayer and the government while striving to resolve disputes in a fair manner while at the same time attempting to remain impartial of both parties.