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Tax & AccountingOctober 18, 2022

Tax professionals and taxpayers can expect improved clarity in IRS Appeals Office Notices

Tax professionals and their tax clients have been frustrated for years in dealing with the Internal Revenue Service Independent Office of Appeals (Appeals Office) when trying to resolve tax disputes without resorting to costly and time-consuming litigation. 

To improve the experience and enhance transparency, the Appeals Office has made two changes to the initial contact letter that should help during the appeals process.

What to expect when challenging an IRS agent's tax finding: the appeals process

When a taxpayer challenges an IRS agent's tax finding, the case is assigned to an Appeals Officer (Officer). The Officer begins by sending a letter to the taxpayer or their representative providing introductory information and inviting that individual(s) to a conference.

Changes to the initial contact letter: contact information

Previously, the letter was unclear regarding options for meeting and didn't provide any information regarding an alternate Appeals contact. The only contact information in the initial contact letter was to the Officer. 

The letter now includes the Appeals Officer's contact information and the name and phone number of the Officer's manager. While the Officer remains the primary contact, having the manager's name will help.

Changes to the initial contact letter: appeals conference options

In addition, the initial contact letter now makes it clear that taxpayers and representatives can choose how they meet with Appeals through conferences that can be held by telephone, video, or in-person. It will make clear that Appeals can work with taxpayers and their representatives through the mail or secure electronic messaging. 

The Appeals Office makes clear in its announcement that these changes in the initial contact letters will be made for most cases received in Appeals, including cases relating to an IRS examination determination, penalties, an offer in compromise, a request for a Collection Due Process hearing or participation in IRS e-file.

IRS Appeals revises initial contact letters as part of effort to enhance the taxpayer experience | Internal Revenue Service

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Mark Friedlich
Vice President of US Affairs for Wolters Kluwer Tax & Accounting
Mark Friedlich, a CPA & tax lawyer, is the Vice President of US Affairs for Wolters Kluwer Tax & Accounting. He is a member of the U.S. Senate Finance Committee’s Chief Tax Counsel’s Advisory Board, advisor to 14 state taxing authorities, and has been a member of the American Bar Association’s Tax Section and AICPA’s Tax Section leadership teams. Prior to joining Wolters Kluwer he was a COO and Principal at PwC.


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