Saturday, September 12, 2015

IRS Terminates Appeals Arbitration (9/12/15)

The IRS has terminated Appeals arbitration.  Rev. Proc. 2015-44, 2015-38 IRB 1, here

I have revised the text of the pdf text books.  In the text of the student edition on p. 346 and of the practitioner edition on p. 491, the following is substitued for the paragraph commencing "The IRS has Appeals mediation."
The IRS tested appeals arbitration for 14 years, but in 2015 decided to discontinue the program.  The IRS still has an Appeals mediation program.  The Appeals mediation process, referred to as the “Post Appeals Mediation,” can be invoked in appropriate cases after the taxpayer and the Appeals Officer have failed to reach agreement as to an issue or issues, but before the Appeals Office closes the case.  Issues eligible and ineligible for mediation are listed in the IRM; thus, for example, legal and factual issues are eligible for mediation.
The significant new citation in the footnotes is Rev. Proc. 2015-44, 2015-38 IRB 1.

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