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…Continue readingAn Impartial IRS Office of Appeals
Category: IRS Appeals
About IRS Appeals
The IRS appeals office provides a second bite at the apple. It is particularly helpful when the IRS agent or auditor was not reasonable; there was a clear mistake made by the IRS in assessing taxes, etc.; or there is a tax dispute that involves a subjective area of tax law.
If you are not familiar with the IRS Office of Appeals, here is a summary of the IRS Office of Appeals function.
This page covers court cases and guidance involving the IRS Office of Appeals. Please scroll down to read the articles.
If you need help filing or preparing an appeal, you can find out more about how we can help with your tax appeal here.
You can also call us at (713) 909-4906.
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…Continue readingIRS Appeals Guidance on In-Person Conferences
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…Continue readingCourt Says No Legal Right to IRS Appeals Review
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…Continue readingIRS Appeals: New Evidence & Theories
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…Continue readingAbout IRS Appeals AJAC Project
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…Continue readingThe IRS’s New Appeals Arbitration Program