Changes to IRS Appeals Conference Procedures May Increase the Role of Actuaries

There has been a significant recent development in the procedures for IRS Appeals conferences. In May 2017, the IRS Appeals Division announced that Appeals Team Case Leader (ATCLs) who volunteer for a pilot program will permit IRS examination personnel and chief counsel attorneys to attend Appeals conferences in all cases the participating ATCLs handle. Under the program, the examination team personnel who proposed the issue, and IRS chief counsel attorneys if requested by the examination team, may attend and participate in the ATCLs conference with the taxpayer, although they may not attend the actual settlement negotiations unless the taxpayer consents. There has been some grumbling by tax practitioners that this procedure impinges on the independence of the Appeals function, and there is something to this complaint. Nevertheless, the program presents an opportunity for the taxpayer to demonstrate the strength of the issue to the examination team and counsel and, possibly, to narrow the issues and project settlements on ongoing issues forward into subsequent cycles.

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