IRS responds: chief of appeals answers CalCPA's letter to IRS.

• Author: Josephs, Stuart R.
• Position: Fed Tax

The March/April 2017 issue of California CPA (Page 19) reported on recent changes in IRS appeals procedures, including conference practices, such as holding conferences by telephone (subject to specified exceptions).

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CalCPA's Committee on Taxation (COT) discussed these changes at its Jan. 10 meeting and decided to send a letter March 8 to the IRS Commissioner, with copies to the Chief of Appeals and the National Taxpayer Advocate, among others.

Excerpts from the COT's Letter

"On behalf of the Committee on Taxation of the California Society of CPAs (CalCPA), we respectfully submit this comment letter to raise significant concerns by California CPAs in light of recent revisions to the Internal Revenue Manual that limit the availability of in-person appeals conferences. As such, we strongly support and echo the concerns raised in the ... joint letter by the Texas Society of Certified Public Accountants and the Tax Section of the Texas Bar Association sent on January 24, 2017.

"... CalCPA's Committee on Taxation works to provide up-to-date information and guidance to members on tax laws, programs and regulations. The committee also renews and responds to proposed tax legislation, regulations and revenue rulings.

"While we support the efforts of the IRS to implement new technologies to reduce costs and increase efficiencies, changes should enhance the taxpayer experience--not come at the expense of taxpayer appeal rights. Face-to-face communications have been critical in resolving matters in appeals, particularly in complex cases or those where supporting documentation may not be easily-shared through technology.

"Further, the guidelines for when an in-person appeals meeting will be granted can be subjective as appeals agents may interpret the guidelines differently. Extended discussions could focus on the merit of an in-person appeals conference rather than the case at hand. Inconsistent interpretation and application of the guidelines can undermine taxpayer confidence in a fair and equitable appeals process.

"Instead of advancing the appeals process, limitations on in-person meetings could reduce the ability of taxpayers and the IRS to clearly communicate their respective positions and will likely extend and complicate the resolution of the issues.

"Face-to-face appeals conferences are important for California CPAs and the taxpayers they represent. We encourage the IRS to not overly restrict the availability of in-person...