IRS Appeals Conferences may now include additional participants. After the conclusion of an IRS Appeals pilot program, the results suggest that IRS Appeals benefits from including examination teams and Chief Counsel attorneys to engage with taxpayers and their representatives at the IRS Appeals conferences. They believe it improves IRS Appeals’ ability to work large, complex cases. In general, IRS Appeals Officers found that the examination team’s participation improved their understanding of the dispute and helped them identify, narrow and resolve factual and legal differences between the parties before engaging in settlement negotiations with taxpayers. Such inclusion of additional parties to the IRS Appeal’s process is at the discretion of the IRS Appeal’s Officer. While there are some concerns by tax practitioners and taxpayers alike, it appears the IRS Appeals ground rules have changed — even if it appears the stack is being decked against taxpayers. Negotiations with three aligned parties is certainly more difficult than negotiations with one party.
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