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Appeals division to change case transfer policy

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Appeals division to change case transfer policyThe 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 8.6.1.4.1, 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.

Contact
David Auclair
National Managing Principal, Washington National Tax Office
+1 202 521 1515

Shamik Trivedi
Manager, Washington National Tax Office
+1 202 521 1511


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