IRS Appeals issues guidance on its new policy

Tax Controversy & Dispute Resolution ()
IRS Appeals set forth a new policy on the handling of cases in Appeals. The new policy reflects the first phase of implementing recommendations from the Appeals Judicial Approach and Culture Project, which is designed to promote a quasi-judicial approach to the way Appeals conducts business.

Primary issues addressed by the project are with situations where new facts, issues, legal theories, or alternative arguments are presented after a case gets to Appeals, and the treatment of cases not fully developed by the Large Business & International Division Examination Division.

The new policy applies to all Appeals actions taken after July 18, 2013, including cases protested to Appeals after that date as well as all open cases in Appeals on that date.