IRS Proposes Procedures to Protect Appeals Settlement Authority - McDermott Will & Emery

IRS Proposes Procedures to Protect Appeals Settlement Authority

Overview


Jean Pawlow addressed proposed new IRS procedures which can refer cases not heard for settlement before going to the Tax Court back to Appeals after docketing. “The rules for moving [a case] from Tax Court back to Appeals were somewhat vague” before, Ms. Pawlow explained. “I’ve definitely had situations [when] the Exam team has essentially told a taxpayer that if they did not sign an extension to the statute of limitations that . . . the taxpayer would not be able to go to Appeals.”