IRS Appeals Team Case Leaders Retain Settlement Authority - McDermott Will & Emery

IRS Appeals Team Case Leaders Retain Settlement Authority

Overview


Jean Pawlow said an IRS letter confirming that appeals team case leaders (ATCLs) will retain complex tax case settlement authority “sounds like a modification [that] will cause uncertainty.” She explained that ATCL managers already have the authority to review settlements and propose changes but internal IRS guidance isn’t clear that such reviews are required, particularly if a manager hasn’t had the opportunity to review an ATCL settlement.