Preparation for Appeals Division conference.

• Author: Anderson, Donald H.
• Position: Brief Article

Practitioners representing clients in the Appeals Division should note that in Internal Revenue Manual Transmittal 42(11)8-38, issued Nov. 10, 1992, the IRS has amended the instructions in its Handbook for Field Examination Case Managers to provide that taxpayers be given a copy of any written rebuttal to an appeals protest.

This rebuttal is usually prepared by the Examination Division on review of a written protest filed by a taxpayer. The rebuttal should highlight the facts that the examiner intends to press and the examiner's rationale, in a more complete way than the examination report itself. The...