About Course

This self-study ethics program examines the practitioner’s professional and ethical responsibilities while representing a client before the IRS Independent Office of Appeals. The course addresses the independence of the Appeals function and the ex parte communication restrictions that protect that independence under Rev. Proc. 2012-18, the standards of Circular 230 §10.34 as applied to preparing a formal protest or small case request, the diligence and candor obligations that govern settlement negotiations with an Appeals Officer, conflicts of interest that can arise when representing related taxpayers in the same matter, the confidentiality expectations surrounding Appeals settlement discussions, and the practitioner’s obligations regarding statutory deadlines that follow the conclusion of an Appeals case.

Explain the independence of the IRS Independent Office of Appeals from Examination and Collection functions
Apply the ex parte communication restrictions of Rev. Proc. 2012-18 to protect the taxpayer's right to a fair Appeals process
Apply the standards of Circular 230 §10.34 to the preparation of a formal protest or small case request
Apply the diligence-as-to-accuracy standard to representations made during Appeals settlement negotiations
Identify the practitioner's duty of candor toward an Appeals Officer during settlement discussions
Identify conflicts of interest specific to representing related taxpayers in the same Appeals matter
Apply the confidentiality expectations governing Appeals settlement discussions
Identify the practitioner's obligations regarding statutory deadlines following the conclusion of an Appeals case

Course Content

Module 1 – The Appeals Function and Ex Parte Communication Restrictions
This module examines the independence of the IRS Independent Office of Appeals from Examination and Collection, and the ex parte communication restrictions of Rev. Proc. 2012-18 that protect that independence.

The Appeals Function and Ex Parte Communication Restrictions

Module 2 – Preparing and Submitting a Valid Protest
This module addresses the standards of Circular 230 §10.34 as applied to preparing a formal written protest or small case request, including the reasonable-basis requirement for positions raised in Appeals.

Module 3 – Settlement Negotiation and the Duty of Candor
This module covers the diligence-as-to-accuracy standard applied to settlement discussions and the practitioner's duty of candor toward an Appeals Officer during negotiation.

Module 4 – Conflicts, Confidentiality, and Post-Appeals Considerations
This module reviews conflicts of interest specific to representing related taxpayers in the same Appeals matter, confidentiality expectations in settlement discussions, and post-Appeals statutory deadline obligations.

Final Assessment – Ethical Responsibilities During IRS Appeals
This final assessment consists of 10 multiple-choice questions covering all four modules of this course. A passing score of 70% or better is required.

About Course

Related Courses

What Will You Learn?

Course Content

Module 1 – The Appeals Function and Ex Parte Communication Restrictions This module examines the independence of the IRS Independent Office of Appeals from Examination and Collection, and the ex parte communication restrictions of Rev. Proc. 2012-18 that protect that independence.

The Appeals Function and Ex Parte Communication Restrictions

Module 2 – Preparing and Submitting a Valid Protest This module addresses the standards of Circular 230 §10.34 as applied to preparing a formal written protest or small case request, including the reasonable-basis requirement for positions raised in Appeals.

Preparing and Submitting a Valid Protest

Module 3 – Settlement Negotiation and the Duty of Candor This module covers the diligence-as-to-accuracy standard applied to settlement discussions and the practitioner's duty of candor toward an Appeals Officer during negotiation.

Settlement Negotiation and the Duty of Candor

Module 4 – Conflicts, Confidentiality, and Post-Appeals Considerations This module reviews conflicts of interest specific to representing related taxpayers in the same Appeals matter, confidentiality expectations in settlement discussions, and post-Appeals statutory deadline obligations.

Conflicts, Confidentiality, and Post-Appeals Considerations

Final Assessment – Ethical Responsibilities During IRS Appeals This final assessment consists of 10 multiple-choice questions covering all four modules of this course. A passing score of 70% or better is required.

Ethical Responsibilities During IRS Appeals

Module 1 – The Appeals Function and Ex Parte Communication Restrictions
This module examines the independence of the IRS Independent Office of Appeals from Examination and Collection, and the ex parte communication restrictions of Rev. Proc. 2012-18 that protect that independence.

Module 2 – Preparing and Submitting a Valid Protest
This module addresses the standards of Circular 230 §10.34 as applied to preparing a formal written protest or small case request, including the reasonable-basis requirement for positions raised in Appeals.

Module 3 – Settlement Negotiation and the Duty of Candor
This module covers the diligence-as-to-accuracy standard applied to settlement discussions and the practitioner's duty of candor toward an Appeals Officer during negotiation.

Module 4 – Conflicts, Confidentiality, and Post-Appeals Considerations
This module reviews conflicts of interest specific to representing related taxpayers in the same Appeals matter, confidentiality expectations in settlement discussions, and post-Appeals statutory deadline obligations.

Final Assessment – Ethical Responsibilities During IRS Appeals
This final assessment consists of 10 multiple-choice questions covering all four modules of this course. A passing score of 70% or better is required.