IRS Pitch on Appeals Office Sparks Fears of More Litigation

Proposed changes to the IRS Appeals office could result in more taxpayers needing to resolve disputes with the IRS through litigation, tax practitioners and other stakeholders warn.

The Appeals office is designed as an alternative to resolving tax controversies through litigation. The IRS and Treasury Department proposed rules in September implementing a portion of the 2019 Taxpayer First Act, which codified and outlined the office’s structure and function. A key portion of the proposed regulations describe 24 circumstances when controversies are not eligible for consideration by Appeals.

Lawyers and others with interest in the proposed rules called them too restrictive, ...