A conversation with the new Chief of Appeals: an interview with Sarah Hall Ingram.

• Author: Dougherty, James A.
• Position: Interview

TEI: Sarah, you've been Chief of Appeals for more than six months now. Is Appeals what you expected? How have you found the state of Appeals?

Sarah Hall Ingram (SHI): I've worked with Appeals throughout my 25 years with the Internal Revenue Service. I have enjoyed joining the organization and working with Appeals from the inside. I am very impressed with the depth of commitment of Appeals employees; they are passionate about their mission and about the services they offer the public.

Whatever the IRS perspective on a case is, I believe you need a place that acts as a safety valve so that disputes can be settled without litigation. Taxpayers and the IRS may have legitimate disagreements to resolve; we need an independent place to look at these disputes in order to reduce litigation burdens for taxpayers and the IRS. Our tax system could not work without this safety valve.

The world is changing, so Appeals will have to continuously adapt as it has over the past years. I find it to be a creative place, interested in becoming ever more nimble. The willingness to be creative and try new things has impressed me.

TEI: What are your major concerns at Appeals?

SHI: We face several issues requiring creativity and focus. First, Appeals must examine the way it approaches hiring and knowledge transfer in light of attrition and the changing workforce. The upcoming retirement of the Baby Boomer generation presents specific challenges at Appeals. Traditionally; Appeals hires people who have already developed a substantial core of experience working within the IRS. This means that many people arrive at Appeals later in their IRS career. Because it is so rewarding, many people have stayed well past retirement eligibility, but we are now facing significant attrition. We are looking at ways to transfer institutional knowledge and experience as much as possible and we are exploring new and creative ways to enhance existing expertise. This may entail tapping different types of expertise within the IRS or hiring outside the IRS, which is not the normal mode of operation at Appeals. We are carefully considering the type and career level of applicants we will pursue. As we articulate exactly what skills sets, job types and locations we are interested in, we intend to work with the AICPA, accounting schools, TEI, and others to identify who might be interested in working with us. Appeals can offer interesting work for tax professionals and by mixing and matching people with inside knowledge and outside experience we'll develop a good give and take inside Appeals. But outside hiring will be a change for us.

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Another concern at Appeals is speeding up case resolution. Appeals' motto is "have skills, will travel." We will take our toolkit and parachute in wherever the system can find our authority and skills helpful. A good example is the Compliance Assurance Process (CAP) in the Large and Mid-Size Business Division (LMSB). As taxpayers and the IRS try to resolve issues prior to a taxpayer filing its return, sometimes disagreements arise. We have been invited by taxpayers and LMSB to use the Fast Track Settlement (FTS) tool to help resolve such disputes, allowing the return to be filed with agreement. We've had success in cases with either a single issue or multiple issues because we bring mediation skills and settlement authority.

Taxpayers and examination teams have utilized our mediation skills and settlement authority during audits as well. The traditional FTS program is effective and has recently been expanded to include Small Business/Self-Employed (SB/SE) taxpayers in a test program. Appeals' efforts to raise awareness of this program, both internally and externally, are increasing the number of FTS requests. FTS is a key way to reduce the number of cases that must be resolved the slower, "old fashioned" way.

TEI: Since around 1995, many practitioners' and taxpayers' experience with resolution programs has been mostly positive. Discrepancies, however, arise. For example, some IRS offices use Fast-Track Settlement or Post-Appeals Mediation and others do not. Why are taxpayers and IRS Appeals Officers reluctant to use the programs? What can be done to increase the numbers?

SHI: Appeals is at a crossroads regarding a number of these programs. We tend to see the same taxpayers and practitioners returning to use the programs after previous positive...