Navigating the IRS Appeals Office Process: Achieving Settlement, Avoiding Litigation

Filing Formal Protests, Appealing Collection Actions, Requesting Collections Due Process Hearings Through Appeals

Recording of a 110-minute CPE webinar with Q&A


Conducted on Wednesday, March 1, 2017
Recorded event now available


This webinar will provide tax advisers and professionals with an advanced guide to navigating the IRS appeals processes. The panel will go beyond the basics to offer an in-depth guide to leveraging the appeals process to challenge not only assessments, but also collections proceedings. The webinar will include specific examples of navigating each stage of the appeals process.

Description

An often overlooked vehicle for resolving taxpayer disputes is the IRS Appeals Office. While many practitioners view the Appeals Office as a last resort measure and focus on trying to reason with a revenue agent, the structure of the Appeals Office and the powers vested in an Appeals Officer may lead to a resolution that cannot be achieved during the examination, and without litigation.

The Appeals Office is charged with the mission of acting to “resolve tax controversies, without litigation, on a basis which is fair and impartial to both the Government and the taxpayer.” As a component of the mission to avoid litigation, Appeals Officers possess broad powers to resolve taxpayer protests and challenges.

The appeals process has several essential steps which CPAs and EAs must navigate, above any strategic considerations. For tax advisers representing clients in IRS disputes, a thorough understanding of the policies and procedures of the Appeals Office is essential to resolving tax controversies.

In October 2016, the Service announced a number of policy changes that impact taxpayers pursuing formal appeals. Even tax advisers who have experience in practicing before the Appeals Office must be aware of these changes to avoid costly mistakes in representing clients before the Appeals Office.

Listen as our experienced panel provides a thoroughly detailed and practical guide to navigating the IRS Appeals Office process to achieve advantageous tax settlements.

Outline

  1. Structure of IRS Appeals Office
    1. Settlement authority vested in Appeals Officers
    2. “Litigation hazards” consideration
    3. Appeal Officers’ authority to reopen previously closed cases and assessments
  2. Process of filing an appeal
  3. Tactics and strategies for pursuing a claim through the Appeals Office
  4. Collection appeals and requesting a collection due process hearing or appeal
  5. Illustrations and examples

Benefits

The panel will discuss these and other critical topics:

  • What challenges may a taxpayer bring to the Appeals Office?
  • How does the requirement that an Appeals Officer consider the “hazards of litigation” serve as an advantage to taxpayers and advisers in bringing an appeal?
  • When should a taxpayer docket a case before going through the appeals process?
  • Using the appeals process to challenge collection actions or address tax assessments that have not yet been challenged
  • How do the policy and procedure changes announced in October 2016 impact taxpayers and advisers pursuing formal appeals?

Learning Objectives

After completing this course, you will be able to:

  • Determine scenarios where a taxpayer may receive a more favorable settlement or resolution by pursuing an appeal through the IRS Appeals Office
  • Recognize how the specific settlement authority and incentives vested in IRS Appeals Officers can be leveraged to a taxpayer’s advantage
  • Discern critical tactical and strategy considerations in pursuing cases through the Appeals Office
  • Identify critical steps in the appeals process

Faculty

Mary I. Slonina, Director
PricewaterhouseCoopers, Washington, D.C.

Ms. Slonina is Director on the Tax Controversy and Regulatory Services team within Washington National Tax Services. She provides guidance and assistance to clients in regards to IRS practice and procedure, including representing clients in administrative interactions with the IRS (Examination, Collection, Office of Appeals, and Chief Counsel). Her areas of concentration include entity classification, FIRPTA transactions, IRS collection actions, penalty abatement relief, statute of limitations, 2014 Offshore Voluntary Disclosure Program (and related disclosure initiatives), and private letter ruling requests (including Treas. Reg. 301.9100 relief).

Elizabeth Askey, Principal
PricewaterhouseCoopers, Washington, D.C.

Ms. Askey is a principal in Pwc’s Tax Controversy and Regulatory Services (TCRS) practice. To this role, she brings more than 20 years of experience in assisting multinational corporations with the prevention and resolution of complex tax controversies. She has represented her clients before the IRS, in litigation, and in policy matters (both regulatory and legislative) before the US Department of the Treasury and the Congressional tax-writing committees. Previously, she held senior positions at Ernst & Young LLP and Pillsbury Winthrop Shaw Pittman LLP. She also formerly served at the US Treasury Department’s Office of Tax Policy, first as an Attorney-Advisor in the Office of Tax Legislative Counsel, and then as Associate Tax Legislative Counsel.


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Program Materials

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Customer Reviews

The conference was technical, informative and presented at a good pace.

Krystal Ching

KMH

I liked the concentration on specific issues and examples.

Edita Rimalovsky

Komisar Brady & Co.

I appreciated the flow of the information offered and the ease at which I could follow the handouts.

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WISS & Company

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Savas Greene & Company

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Sample and Bailey

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