The following is an excerpt from the article “Tips For Representing Your Client Before The Appeals Division Of The Internal Revenue Service“, by Sam Braunstein and Robb A. Longman. It was published in The Practical Tax Lawyer, Winter 2006.
There are numerous levels of interaction between taxpayers and the Internal Revenue Service. The most familiar are the office auditors and field auditors (Tax Examiners and Revenue Agents) and collection agents (Revenue Officers). When taxpayers are unable to resolve a tax matter with one of these branches of the Service, they may have an opportunity to discuss their case with the Appeals Division.
The Appeals Division of the Internal Revenue Service is composed of Appeals Officers, many of whom are attorneys or certified public accountants with many years of experience, who handle cases that could not be resolved during their initial stages. They attempt to settle their cases by negotiating with the taxpayers in an effort to resolve the cases without litigation—which is their primary function. Appeals have the ability to effectively resolve many cases when there are continuing disputes because they are a separate and an independent division of the IRS. Additionally, because of their independence, working with Appeals can usually save the taxpayer time and money.