Navigating the IRS Appeals Office Process: Achieving Settlement, Avoiding Litigation

Description

An often overlooked vehicle for resolving taxpayer disputes is the IRS Appeals Office. While many practitioners view the Appeals Office as a last resort measure and focus on trying to reason with a revenue agent, the structure of the Appeals Office and the powers vested in an Appeals Officer may lead to a resolution that cannot be achieved during the examination, and without litigation.

The Appeals Office is charged with the mission of acting to “resolve tax controversies, without litigation, on a basis which is fair and impartial to both the Government and the taxpayer.” As a component of the mission to avoid litigation, Appeals Officers possess broad powers to resolve taxpayer protests and challenges.

The appeals process has several essential steps which CPAs and EAs must navigate, above any strategic considerations. For tax advisers representing clients in IRS disputes, a thorough understanding of the policies and procedures of the Appeals Office is essential to resolving tax controversies.

In October 2016, the Service announced a number of policy changes that impact taxpayers pursuing formal appeals. Even tax advisers who have experience in practicing before the Appeals Office must be aware of these changes to avoid costly mistakes in representing clients before the Appeals Office.

Listen as our experienced panel provides a thoroughly detailed and practical guide to navigating the IRS Appeals Office process to achieve advantageous tax settlements.