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IRS Appeals Tax Procedure

An Impartial IRS Office of Appeals

While IRS auditors and IRS attorneys typically focus on imposing the most tax possible, the IRS Office of Appeals does not. Appeals is tasked with settling cases. In doing so, Appeals is supposed to be impartial. This allows Appeals to ‘get it right.’ The recent Onyeani v. Commissioner, T.C. Memo. 2020-15 provides an opportunity to […]

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IRS Appeals Tax Procedure

IRS Appeals Guidance on In-Person Conferences

The IRS Office of Appeals has been making changes to how it conducts appeals conferences.  In this past few years, these changes have made it difficult to obtain an in-person conference.  The IRS recently issued interim guidance AP-08-1118-0013 to authorize appeals to allow for more in-person conferences. About the IRS Office of Appeals The IRS […]

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IRS Appeals Tax Procedure

Court Says No Legal Right to IRS Appeals Review

Does the Taxpayer Bill of Rights create a legal right to have a tax dispute considered by the IRS Office of Appeals?  The court recently addressed this question in Facebook, Inc. v. Internal Revenue Service, No. 17-cv-06490-LB (N.D. Calif. 2018), concluding that there is no legal right to have an administrative appeal for a tax dispute. Facts […]

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IRS Appeals IRS Audits Tax Procedure

IRS Appeals: New Evidence & Theories

The IRS released a memo describing Phase II of the Appeals Judicial Approach and Culture (AJAC) program. This program is intended to formalize many of the best practices of the IRS Office of Appeals (Appeals). Tax disputes often end up in Appeals. Appeals is able to successfully resolve or settle most cases. The Appeals process […]

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IRS Appeals IRS Audits Tax Procedure

About IRS Appeals AJAC Project

The IRS Office of Appeals just released a memo describing its changes pursuant to its¬†Appeals Judicial Approach Culture (AJAC) project.¬† These changes do not really break new ground, but they address a few key issues that are often in dispute in appeals cases. About the IRS Office of Appeals The IRS Office of Appeals is […]

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IRS Appeals IRS Audits Tax Procedure

The IRS’s New Appeals Arbitration Program

The IRS Office of Appeals provides a great forum for resolving IRS tax disputes.  While appeals settles a lot of cases, it doesn’t settle them all.  This is where the IRS arbitration program comes in.  It is for those close cases that almost settled, but didn’t.  The IRS recently released Revenue Procedure 2006-44, which sets out […]