The IRS Independent Office of Appeals (“IRS Appeals”) was established to provide an “independent” IRS function that is separate and independent from the IRS’s compliance functions that maintain responsibility for collecting and assessing taxes. By statute, its function is to resolve tax controversies without litigation on a basis that: (1) is fair and impartial to both the IRS and the taxpayer; (2) promotes a consistent application and interpretation of, and voluntary compliance with, federal tax laws; and (3) enhances public confidence in the integrity and efficiency of IRS.
IRS Appeals has been around—by one name or another—for almost a century. Section 1001 of the 2019 Taxpayer First Act renamed the IRS Office of Appeals to the IRS Independent Office of Appeals. But most of its operations remained the same.
IRS Appeals plays an important role in the IRS’s overall structure. Indeed, it resolves more than 100,000 tax cases every year. Perhaps the two most common avenues for such resolutions are Collection Due Process Hearings and appeals pursuant to the Collection Appeals Program.
The Origins of the Current IRS Appeals
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