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IRS considers changes to appeals rules

Michigan residents will understandably be concerned regarding possible changes in the manner in which the IRS handles tax appeals. Currently, the IRS provides 35 Appeals team case leaders (ATCLs) settlement authority regarding these cases. However, the IRS may in the future place the resolution of complex tax cases involving significant dollar amounts in the hands of specific managers. The IRS apparently wishes for more consistent results in the appeals process.

However, there is concern among tax attorneys that such a change may instead make the appeals process weaker. Current cases involve hearings in front of a panel consisting of four or five appeals officers. Contrary to IRS assertions, the current process limits the amount of control that one particular officer may have in deciding a case and prevents inconsistency.

There is also concern that the proposed changes will actually slow the process down. Backlogs may occur due to new requirements for ACTLs to first require approval by a manager. As these managers were not present at the hearings, it may also take the manager time to get up to speed on what the case is about.

Regardless of what rules are in place, since most taxpayers do not deal with the tax code or tax matters on a daily basis, understanding the issues at stake during a tax audit or appeal can be extremely difficult. The penalties for reporting errors can be severe. Also, because of IRS deadlines, the need for immediate action is often necessary.

In the event of an IRS audit or lien, having tax representation on your side is very beneficial. This is because experienced tax attorneys routinely deal with such complex tax controversies.

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