IRS Appeals and Tax Court Trends: FY 2021 to 2025

What the five-year data show

• Appeals closed 81,471 cases in FY 2023 and 52,997 in FY 2025.
• Appeals inventory rose from 33,428 to 40,313 cases during FY 2025.
• Tax and penalties in dispute in pending Tax Court cases rose from $26.6 billion at the end of FY 2021 to $53.1 billion at the end of FY 2025.

Appeals inventory rose as closures fell

Appeals received 60,933 cases and closed 52,997 in FY 2025. Its year-end inventory increased 21% from FY 2024. Collection Due Process receipts and pending inventory also increased. Those measures may signal delay pressure, but timing varies with the issue, the office, the record, and whether a hearing can be resolved without a conference.

The Tax Court docket has fewer cases and more dollars in dispute

Petitions received fell from 34,645 in FY 2022 to 19,189 in FY 2025. Yet the amount in dispute in pending cases increased to $53.1 billion. Dividing the two published measures produces an average of roughly $2.5 million per pending case in FY 2025, compared with about $800,000 in FY 2021. That arithmetic is a description of the aggregate docket, not a prediction of any case's value or complexity.

What this means in a live dispute

An unagreed examination result can create a potential dispute, but it does not establish that a matter will enter Appeals or reach Tax Court. The practical questions are the proposed adjustment, the factual record, the available forum, and the deadline. For a notice of deficiency, review the firm's 90-day letter guide. For a lien or levy notice, the collection hearing deadline should be addressed promptly.

Methodology and sources

Appeals figures are from IRS Data Book Table 4-3. Tax Court figures are from Chief Counsel Table 5-2. Amounts in dispute reflect the tax and penalties stated in petitions, not final liability. The IRS collections, penalties, and Appeals tables and IRS Data Book archive provide the underlying annual material.