The Internal Revenue Service is on one side and a group of tax controversy attorneys are on the other side. At issue is a change under consideration by the IRS in resolutions of complex, high-value appeals disputes.
The federal agency wants to shift settlement authority in those cases into the hands of a small group of appeals case managers, which would have the effect of narrowing and weakening the tax appeals process, the attorneys told a media outlet.
Currently, 35 appeals team case leaders in offices across the nation have settlement authority. The shift would move that authority into the hands of the half-dozen managers of those team leaders.
The IRS insists the move would help correct a "significant control weakness" in its "Penalty Appeals workstream." The proposed change has not been finalized, and the IRS says it will decide on the matter "in due course."
A tax controversy attorney told Bloomberg BNA that the IRS is trying to make settlements more consistent by reducing the opportunity for "rogue" appeals officers to forge bad deals. The attorney said he believes the agency's rationale does not make much sense, given that in high-dollar, complex cases, there are multiple appeals officers in on the matter anyway.
He said the change might well create a bottleneck in the appeals process, slowing things down. We will have more on the proposed appeals settlement change in our next post.
But in the meantime, if you need the help of an IRS tax lawyer, the criminal tax experts of Robert J. Fedor, Esq., LLC can help navigate the course for your tax issues.