Part 8. Appeals
Table of Contents
8.1 Appeals Function- 8.1.1 Appeals Operating Directives and Guidelines
- 8.1.3 Working Cases in Appeals
- 8.1.6 Disclosure, Security and Outside Contacts
- 8.1.7 AQMS Purpose and Guidelines
- 8.1.8 Employee Tax Compliance
- 8.1.9 Closed Case Referrals and Customer Service Contacts
- 8.1.10 Ex Parte Communications
- 8.2.1 Agreed Pre-90-Day Income Tax Cases
- 8.2.2 Statutory Notice of Deficiency Cases
- 8.2.3 Related, Whipsaw and Inactive Cases
- 8.4.1 Procedures for Processing and Settling Docketed Cases
- 8.4.2 Campus Appeals Docketed Cases
- 8.4.4 Examination Assistance Requests
- 8.6.1 Conference and Issue Resolution
- 8.6.2 Appeals Case Memo Procedures
- 8.6.3 Appeals Rulings
- 8.6.4 Reaching Settlement and Securing an Appeals Agreement Form
- 8.6.5 Identity Theft Procedures
- 8.7.1 Guidelines for Cases with Special Issues
- 8.7.3 Domestic and International Operations Programs
- 8.7.4 Appeals Estate and Gift Tax Cases
- 8.7.5 Transferee and Transferor Liabilities
- 8.7.6 Appeals Bankruptcy Cases
- 8.7.7 Claim and Overassessment Cases
- 8.7.8 Tax Exempt and Government Entities (TE/GE) Cases
- 8.7.9 Joint Committee (JC) Cases
- 8.7.10 Excise Tax Cases and IRA Adjustments
- 8.7.11 Working Appeals Team Cases
- 8.7.12 Appeals Innocent Spouse Case Procedures
- 8.7.13 e-file Cases
- 8.7.14 Freedom of Information Act (FOIA) Administrative Appeal Cases
- 8.7.15 Administrative Cost and Qualified Offer Cases
- 8.7.16 Appeals Employment Tax Procedures
- 8.7.17 Appeals Remittance Procedures
- 8.7.18 Return Preparer Misconduct Cases
- 8.7.19 Net Rate Netting Procedures for Appeals
- 8.7.20 Appeals Cases Involving Shared Responsibility Payment (SRP) Under IRC 5000A
- 8.7.21 Employer Shared Responsibility Payment (ESRP) Under IRC 4980H
- 8.11.1 Return Related Penalties in Appeals
- 8.11.3 Return Preparer Penalty Cases
- 8.11.4 Penalty Appeals (PENAP)
- 8.11.5 International Penalties
- 8.11.6 FBAR Penalties
- 8.11.7 Abusive Transaction Penalties
- 8.11.8 Miscellaneous Penalties
- 8.17.2 General Settlement and Rule 155 Computations
- 8.17.3 Preparing a Statement of Account
- 8.17.4 Notices of Deficiency
- 8.17.5 Special Computation Formats, Forms and Worksheets
- 8.17.6 Interest Issues in Settlement Computations
- 8.17.7 Penalties/Additions to Tax in Computations
- 8.19.1 Procedures and Authorities
- 8.19.2 Managers/TEFRA Resources
- 8.19.6 Partner Cases
- 8.19.7 Administrative Adjustment Request
- 8.19.8 Collection Cases
- 8.19.9 Non-TEFRA Procedures
- 8.19.10 Receipt, Assignment, and Consideration of TEFRA Partnership Cases
- 8.19.11 Agreed TEFRA Partnership Cases
- 8.19.12 Final Partnership Administrative Adjustment
- 8.19.13 Docketed and Department of Justice Cases
- 8.19.14 Bipartisan Budget Act of 2015 Procedures
- 8.20.3 Appeals Centralized Database System (ACDS)
- 8.20.5 Carding New Receipts
- 8.20.6 Interim Actions
- 8.20.7 Closing Procedures
- 8.20.10 Appeals Processing Employee Automated System (PEAS)
- 8.21.1 General Statute Responsibility
- 8.21.2 Account and Processing Support (APS) Statute Responsibility
- 8.21.3 Appeals Technical Employees Statute Responsibility
- 8.21.4 Appeals Management Statute Responsibility
- 8.21.5 Statutes on Collection Cases
- 8.21.6 Statute Information on TEFRA Cases
- 8.21.7 Barred Statute Procedures
- 8.22.4 Collection Due Process Appeals Program
- 8.22.5 Receipt, Control and Pre-Conference Considerations
- 8.22.6 Cases Requiring Special Handling
- 8.22.7 Alternatives to Collection Action
- 8.22.8 Liability Issues and Relief from Liability
- 8.22.9 Closing and Post Closing Actions
- 8.23.1 Offer in Compromise Overview
- 8.23.2 Receipt and Control of Non-Collection Due Process (CDP) Offers
- 8.23.3 Evaluation of Offers in Compromise
- 8.23.4 Acceptance, Rejection, Withdrawal and Default Procedures for Non-Collection Due Process (CDP) Offers
- 8.23.7 Doubt as to Liability
- 8.25.1 Trust Fund Recovery Penalty (TFRP) Overview and Authority
- 8.25.2 Working Trust Fund Recovery Penalty Cases in Appeals
- 8.26.1 Fast Track Settlement for Large Business and International (LB&I) Taxpayers
- 8.26.2 Fast Track Settlement for Small Business/Self Employed (SB/SE) Taxpayers
- 8.26.3 Fast Track Mediation for Collection Cases
- 8.26.4 Early Referral Procedures
- 8.26.5 Post Appeals Mediation (PAM) Procedures for Non-Collection Cases
- 8.26.7 Fast Track Settlement (FTS) for Tax-Exempt/Government Entities (TE/GE) Taxpayers
- 8.26.8 Compliance Assurance Process - Fast Track Settlement
- 8.26.9 Post-Appeals Mediation Procedures for Collection Cases
- 8.26.11 Rapid Appeals Process (RAP)