IRS Letter 854C: Penalty Relief Denied, Appeal Rights Explained
The IRS denied all or part of your request to remove or waive a penalty. The letter explains why and how to appeal.
Numbers covered by this guide
Letter 854C
Letter 852C
Letter 853C
Check the identifier and follow the instructions on your own notice.
Published by the Law Offices of Darrin T. Mish, P.A.•Updated March 18, 2026
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Notice
Letter 854C / Letter 852C / Letter 853C
Urgency
Urgent
Deadline
Appeal by the date and method on the letter
Your first move
Read the reason for the denial, then decide whether to send new information or a signed written appeal.
See it explained
Letter 854C in plain English
Letter 854C: what it means, in 30 secondsA 30-second overview from tax attorney Darrin T. Mish: what this notice is, the deadline, and your first move.
Letter 854C is titled Penalty Waiver or Abatement Disallowed/Appeals Procedure Explained. The IRS sends it when it fully or partially denies a request to remove (abate) or waive a penalty. It is not an identity verification letter.
What This Letter Means
You, or someone on your behalf, asked the IRS to take a penalty off your account. That request may have been a reasonable cause statement, a first-time abatement request, or another penalty relief argument. The IRS reviewed it and said no to some or all of it. The penalty stays on the account.
The letter should state the specific reason the request was denied. It also explains your appeal rights and the steps you must follow if you want the IRS Independent Office of Appeals to review the decision.
Your Options
Send new information. If you have facts or documents the IRS did not see, send them. The IRS reviews a reply for new information that would allow the penalty to be removed before it goes any further.
Request an appeal. If you disagree and want Appeals to review the denial, follow the protest instructions in the letter. The appeal request must be in writing and signed by you or by a representative with a valid Form 2848 on file.
Accept the decision. If you agree, pay the penalty and any interest to stop further interest from building.
Deadlines
Use the response date and instructions printed on your letter. If you paid the penalty and may want to sue for a refund later, the refund suit deadlines are technical. Get advice on that before relying on any timeline.
Practical Tips
Keep a copy of the letter.
Address the exact reason the IRS gave for the denial. Repeating your first request word for word rarely changes the result.
Send your response by a trackable method and keep proof of mailing.
If the IRS denied your penalty relief request and you want to appeal, call us at (813) 229-7100.
This letter has a clock on it. Don’t run it out alone.
Free consultation with Darrin T. Mish, a Tampa tax attorney licensed since 1993 and admitted to the U.S. Tax Court. Bring the letter.