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 18.104.22.168.1, 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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