On July 2, 2014, the Department of Treasury issued a memorandum that provides guidance to Appeals employees on implementation of the Appeals Judicial Approach and Culture Project (hereinafter “AJAC Project”), which will affect multiple sections of the Internal Revenue Manual (hereinafter “IRM”). The AJAC Project is reinforcing Appeals’ quasi-judicial approach to the way it handles cases, with the goal of improving internal and external taxpayer perceptions of a fair, impartial and independent Office of Appeals.

The memorandum contains attachments that provide guidance pertaining to all Appeals employees who open and close cases and hold hearings, conferences or otherwise resolve open case issues in the affected Examination work streams in Appeals. The guidance generally applies to non-docketed cases and does not change any practice with respect to docketed cases. Similar procedures for docketed cases are anticipated to be issued before year-end.

The effective date of the memorandum is September 2, 2014, except for IRM 8.4.1.15.4, which has an effective date of October 1, 2014. The guidance is in effect for all new Appeals case receipts on or after Sept. 2, 2014, and will be incorporated into the IRM within two years from the effective date of the memorandum. The Department of Treasury memorandum can be located HERE.

For legislative updates from Capitol Hill and complete coverage of the latest statutory, administrative, and judicial interpretations please connect with me on TaxConnections.