The IRS on Aug. 24 updated the Internal Revenue Manual (IRM) to
reflect changes to the way the Appeals Division functions,
specifically impacting the ability for a taxpayer in Appeals to
receive a face-to-face meeting.
IRM 126.96.36.199.1, which became effective on Oct. 1, states that
whenever possible, Appeals conferences should be conducted over the
telephone, or if possible, through virtual service delivery, such
as a video conference. An in-person conference is still available,
but will be conducted at the discretion of the Appeals officer. The
IRM provides several examples of when an in-person conference is
appropriate, such as when there are substantial books and records
that cannot be easily reviewed with page numbers or indices, where
the Appeals Division cannot judge the credibility of oral testimony
without an in-person conference, when a taxpayer has special needs
that may be accommodated only through an in-person conference or
when there are numerous participants in the conference that create
the risk of unauthorized disclosure of taxpayer information, among
In the past, IRS officials have discussed the practice of some
taxpayers requesting face-to-face meetings for their appeal in
order to have their case transferred from the IRS's Campus
appeals function to the field appeals function. The IRS's field
appeals function typically handles more complex cases, and some
taxpayers believed that taking up the appeal with those field
officers would be more taxpayer favorable. The IRS has said that
the changes to the procedures are designed to better allocate
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guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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8 Dec 2016, Webinar, Washington, DC, United States
As organizations gear up for the April 10, 2017 implementation deadline, they are making changes to product line ups, pricing, technology, business processes, distribution, their workforce – and in some cases are even changing their business models themselves. Is your organization ready? This webcast will discuss key trends and tactics that have emerged as financial service organizations tackle implementation challenges and highlight emerging best practices.
Program Content: Continued efforts to reform state and local tax (SALT) regimes by state legislatures, courts, tax authorities and the Multistate Tax Commission are transforming the way businesses are reporting their income tax obligations to the states. Evidence of those changes includes the shift to market-based sourcing, mandatory unitary combined reporting and other provisions. Businesses are also trying to come up with approaches to handle indirect tax complexity in light of legislation and litigation challenging the Quill physical presence rule. In addition, the recent federal and state elections’ effect on the SALT landscape will come into focus.
On October 5th, 2016, the Internal Revenue Service and Treasury Department published final, temporary and reproposed regulations1 under Sections 707 and 752 of the Internal Revenue Code of 1986, as amended.
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