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The IRS Office of Appeals

Deciphering who has settlement authority

A major goal of the Internal Revenue Service’s (IRS’s) issue management strategy is consistent resolution of compliance issues. This goal appears to have produced a shift in how the IRS Appeals Division settles cases. Some practitioners have noted less flexibility and greater reliance on uniform settlement terms recently — including Appeals Officers coming to the table with settlement terms already defined. To protect their interests, taxpayers should make sure they interact directly with Appeals decision makers. But in this environment, determining who has settlement authority is not as easy as it once was.
In this article, Deloitte discusses Appeals procedures and strategies to include:

  • Appeals mission, structure, and settlement approach
  • Coordinated issues and settlement authority
  • IRS issue management strategy and its effect on appeals independence
  • Fast Track Settlement
  • Post Appeals Mediation
  • Protecting taxpayer interests
  • Proposed modifications to ex parte rules

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As used in this document, “Deloitte” means Deloitte Tax LLP, a subsidiary of Deloitte LLP. Please see www.deloitte.com/us/about for a detailed description of the legal structure of Deloitte LLP and its subsidiaries.
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