There is not a lot you can do through the IRS structure except take it to court and then through the court appeals line as far up as you can go. You may also try to get a congressional representative involved in the process. It may be a case of differing interpretations on the reading of a statute. Once you take something to the tax court side of things the IRS has a whole different appeals route that takes into consideration the hazards of litigation and are often settled just to stave those off. Can you provide anymore details about the situation and the steps that have already been taken? Feel free to send me a private message via my profile.