Purpose: This IRM section provides a basic overview on:

Audience: Appeals employees

Policy Owner: Director, Case and Operations Support

Program Owner: Director, Policy, Planning, Quality and Analysis

Contact Information: Appeals employees should follow established procedures on How to Contact an Analyst. Other employees should contact the "Content Point of Contact" shown on the Product Catalog Results page for this IRM section.

Appeals responsibility includes but is not limited to the administrative determination of liability, including additions to tax, additional amounts and penalties for the following types of cases:

Cases are established, updated and closed using the following automated systems:

The following systems provide additional research information on cases handled by Appeals:

Generally, Account and Processing Support (APS) uses the systems to establish, maintain and close cases in Appeals. However, all Appeals employees have an interest in the information on some of the systems. The following subsections briefly describe the more commonly used systems.

To accomplish the Appeals mission, it is essential taxpayers have a prompt and independent review when they disagree with the changes proposed by Compliance.

Appeals provides the final administrative opportunity to the taxpayer and the IRS to resolve tax disputes fairly and without litigation. It is essential Appeals earn the respect and trust of taxpayers and practitioners. One aspect of this activity is presenting a unified Appeals position to taxpayers and/or practitioners when settling an issue. See IRM 8.1.1.2, Accomplishing the Appeals Mission.

Appeals Technical Employee (ATE) is an umbrella term used to refer to Appeals employees in the various technical positions. See IRM 8.1.1-1 for a list of positions.

Account and Processing Support (APS) employees play an active role in processing the cases received in Appeals.

For management information, see IRM 1.4.28, Appeals Managers Procedures.

The Appeals Officer (AO) works cases with issues ranging from the simplest to the most complex, and from few to millions of dollars. To successfully accomplish this, they must:

In cases where the AO and the taxpayer succeed in reaching agreement it is important all aspects of the case be fully discussed so all parties understand the issue(s), particularly when agreement is based on hazards of litigation.

However, when a satisfactory basis of settlement cannot be reached, the AO must explain the procedural rights of appeal to the extent necessary to ensure taxpayers and representatives understand these rights.

An AO meets with people from all walks of life whose trust must be earned if satisfactory dealings are to be accomplished.

Experience has shown, when an AO is able to enlist the cooperation of taxpayers and representatives, cases are resolved on a mutually satisfactory basis with minimum expense, delay, and inconvenience to taxpayers.

The Appeals Team Case Leader (ATCL) primarily works Coordinated Industry Cases (CIC) / Large Corporate Compliance (LCC) returns. These cases contain high dollar amounts and very complex issues. Most of these cases are worked in a team format.

The ATCL leads Appeals Officers, technicians, and other support personnel in working team cases. They are responsible for planning the team's work taking into consideration any organizational priorities and necessities.

It is important the ATCL ensure the work is completed in a timely manner. The ATCL does this by assigning team work, monitoring team members’ progress on assignments, and personally working a variety of the most demanding team case issues. If there are problems, the ATCL takes immediate corrective action so there is no adverse impact on resolving the case.

The ATCL provides feedback to team members and their immediate managers, and serves as a mentor and coach to team members to enhance their performance and settlement skills. The feedback is both written and oral, provided on a timely and ongoing basis, and addresses the appropriate critical job elements and aspects. When necessary, the ATCL apprises management of critical or sensitive work related matters.

While the case is in Appeals, the ATCL prepares and updates work plans including directing team members to ensure the progression of the case and overseeing the team members during the settlement conferences and/or team meetings with the largest corporate taxpayers and their representatives, Counsel, and other IRS employees.

The ATCL exercises overall responsibility for arriving at the final disposition of the work unit from the Government’s perspective, including authority to overrule recommendations made by team members on the settlement of their assigned issues, and to approve the final settlement.

The Appeals Account Resolution Specialists (AARS) team employees work the Appeals Customer Service line handling inquiries for various case types; open, unassigned, assigned, closed, and not yet in Appeals. The AARS team also receives closed case referrals (also known as back-end account resolution referrals) to resolve account problems on closed Appeals cases. See IRM 8.1.9 , Closed Case Referrals and Customer Service Contact. These services are available to internal and external Appeals customers including:

Examples of the types of back-end account resolution problems handled by AARS are:

The AARS team does not perform back end processing for:

Generally the AARS team analyzes taxpayer responses and initiates further contact to identify potential liability and to provide technical and procedural information to taxpayers and the taxpayer's representative by correspondence, telephone and in person.

The AARS team researches and analyzes several automated and manual systems to find necessary information, such as:

The AARS team will often initiate adjustments on tax accounts to ensure proper assessments, application of payments, and to resolve disputes between Compliance and the taxpayer.

In addition to the AARS customer service team, AARS employees within Collection Appeals monitor suspended cases and work simpler type collection cases.

Specialized Examination Programs and Referrals (SEPR), which includes Domestic Operations and International Operations, ensures nationwide uniform and consistent settlement of issues, enhances the identification and timely resolution of issues, and provides a vehicle for coordination of technical issues.

The Technical Specialist provides coordination and expertise to Appeals management and ATEs in the following areas:

In order to develop issue experts who are available to assist ATEs in the settlement of their cases, the Technical Specialist:

It is important for the ATE to involve the Technical Specialist early in the case and to continue to include the Technical Specialist throughout the case. When there’s open communication throughout the settlement process, it’s less likely there will be unanswered questions during the R&C process.

Similar to the functions of Technical Specialists, Economists and Engineers provide coordination and expertise to Appeals management and ATEs on issues.

Economists and Engineers are assigned to cases as consultants or team members.

This section provides an overview of the role and responsibility of the Appeals Tax Computation Specialist (TCS) and the important assistance they provide to the ATEs and APS employees.

The TCS organization reports to the Director, SEPR. TCS is comprised of TCS teams, each supervised by an Appeals Tax Computation Team Manager (ATCTM). Each team may consist of one or more Large Case TCS, Senior TCS and other TCS employees.

In addition to their other responsibilities, the Tax Computation Specialist prepares the following:

The TCS provides valuable services which relieve the ATE and APS of time-consuming, detailed computational/technical analysis so more time is devoted to the settlement or processing of disputed cases.

In order to properly aid the ATE or APS, the TCS must:

The Account and Processing Support (APS) employees provide technical assistance and support for controlling and processing tax cases for Appeals and Counsel. APS performs the full range of interim and closing actions which include the following:

The following provides a brief description of the employees in the APS organization and their role:

The Shared Team of Administrative & Redaction Support (STARS) employees provide administrative and redaction support to Appeals employees. STARS employees’ case-related activities include: