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…

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…

The IRS’s New Appeals Arbitration Program

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…