The IRS on Aug. 24 updated
the Internal Revenue Manual (IRM) to reflect changes to the way the Appeals Division functions, specifically impacting the ability for a taxpayer in Appeals to receive a face-to-face meeting.
IRM 18.104.22.168.1, which became effective on Oct. 1, states that whenever possible, Appeals conferences should be conducted over the telephone, or if possible, through virtual service delivery, such as a video conference. An in-person conference is still available, but will be conducted at the discretion of the Appeals officer. The IRM provides several examples of when an in-person conference is appropriate, such as when there are substantial books and records that cannot be easily reviewed with page numbers or indices, where the Appeals Division cannot judge the credibility of oral testimony without an in-person conference, when a taxpayer has special needs that may be accommodated only through an in-person conference or when there are numerous participants in the conference that create the risk of unauthorized disclosure of taxpayer information, among other things.
In the past, IRS officials have discussed the practice of some taxpayers requesting face-to-face meetings for their appeal in order to have their case transferred from the IRS’s Campus appeals function to the field appeals function. The IRS’s field appeals function typically handles more complex cases, and some taxpayers believed that taking up the appeal with those field officers would be more taxpayer favorable. The IRS has said that the changes to the procedures are designed to better allocate resources.
National Managing Principal, Washington National Tax Office
+1 202 521 1515
Manager, Washington National Tax Office
+1 202 521 1511
Tax professional standards statement
This content supports Grant Thornton LLP’s marketing of professional services and is not written tax advice directed at the particular facts and circumstances of any person. If you are interested in the topics presented herein, we encourage you to contact us or an independent tax professional to discuss their potential application to your particular situation. Nothing herein shall be construed as imposing a limitation on any person from disclosing the tax treatment or tax structure of any matter addressed herein. To the extent this content may be considered to contain written tax advice, any written advice contained in, forwarded with or attached to this content is not intended by Grant Thornton LLP to be used, and cannot be used, by any person for the purpose of avoiding penalties that may be imposed under the Internal Revenue Code.
The information contained herein is general in nature and is based on authorities that are subject to change. It is not, and should not be construed as, accounting, legal or tax advice provided by Grant Thornton LLP to the reader. This material may not be applicable to, or suitable for, the reader’s specific circumstances or needs and may require consideration of tax and nontax factors not described herein. Contact Grant Thornton LLP or other tax professionals prior to taking any action based upon this information. Changes in tax laws or other factors could affect, on a prospective or retroactive basis, the information contained herein; Grant Thornton LLP assumes no obligation to inform the reader of any such changes. All references to “Section,” “Sec.,” or “§” refer to the Internal Revenue Code of 1986, as amended.