IRS Practice Before the Office of Appeals

Categories: IRS CE, IRS Resolution
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About Course

This two-hour continuing education course provides tax professionals with an advanced, practical understanding of practice before the IRS Independent Office of Appeals. The course is designed for enrolled agents and other tax return preparers who represent clients seeking administrative review of an IRS determination, and who need a deeper working command of Appeals procedure, conference practice, and settlement authority than a general audit representation course provides.

Participants examine the Independent Office of Appeals’ statutory independence and mission, the ex parte communication restrictions that preserve that independence, and the Taxpayer Bill of Rights protections that apply throughout the Appeals process. The course provides detailed coverage of how to request an Appeals conference — including the formal written protest, the small case request procedure, and Collection Due Process appeals — and of the Appeals conference itself, including the hazards-of-litigation settlement standard, the Appeals Judicial Approach and Culture (AJAC) restrictions, and the Fast Track Settlement, Fast Track Mediation, and Post-Appeals Mediation programs.

The course concludes with practitioner strategy for effective protests and conferences, the post-Appeals options available to a client who does not resolve the case, and Circular 230 considerations specific to Appeals practice.

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What Will You Learn?

  • Identify the statutory independence and mission of the IRS Independent Office of Appeals and the ex parte communication restrictions that protect it
  • Apply the procedural requirements for requesting an Appeals conference, including the formal written protest, the small case request, and Collection Due Process appeals
  • Apply the hazards-of-litigation settlement standard and the Appeals Judicial Approach and Culture restrictions to the Appeals conference process
  • Identify the Fast Track Settlement, Fast Track Mediation, and Post-Appeals Mediation programs and when each is appropriate
  • Apply effective practitioner strategy in preparing a protest and presenting a case to Appeals
  • Identify the post-Appeals options available to a client and apply Circular 230 standards specific to Appeals representation

Course Content

Module 1 – The Independent Office of Appeals — Structure, Mission, and Taxpayer Rights
This module covers the Independent Office of Appeals' statutory independence under the Taxpayer First Act, its settlement-oriented mission, the ex parte communication restrictions that separate Appeals from IRS compliance functions, and the Taxpayer Bill of Rights protections most relevant to Appeals practice.

  • The Independent Office of Appeals — Structure, Mission, and Taxpayer Rights

Module 2 – Requesting an Appeals Conference — Protests, Small Case Requests, and Collection Due Process
This module walks through the procedural paths for requesting Appeals consideration: the formal written protest, the small case request for smaller-dollar cases, the timeliness deadlines following a 30-day letter, and Collection Due Process appeals under Form 12153.

Module 3 – The Appeals Conference and Settlement Process
This module examines how the Appeals conference itself works, including the hazards-of-litigation settlement standard, the Appeals Judicial Approach and Culture (AJAC) restrictions on new issues, and the Fast Track Settlement, Fast Track Mediation, and Post-Appeals Mediation alternatives.

Module 4 – Practitioner Strategy, Post-Appeals Options, and Circular 230 Considerations
The final module addresses practitioner strategy for an effective protest and conference, the post-Appeals options available when a case does not settle, Tax Court petition and refund suit deadlines, and Circular 230 considerations specific to Appeals representation.

Final Assessment – IRS Practice Before the Office of Appeals
You have completed a comprehensive review of practice before the IRS Independent Office of Appeals, covering Appeals' statutory independence and mission, the procedures for requesting an Appeals conference, the hazards-of-litigation settlement process, and practitioner strategy and post-Appeals options. You are now prepared to demonstrate your understanding of the key concepts. The following final examination assesses your knowledge of the material covered in all four modules. A passing score of 70% is required to successfully complete the course.

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