As tax practitioners, it is our job to ask the IRS for relief for our clients. Relief can include a request for an installment agreement, a request for penalty abatement, a request for innocent spouse relief or an Offer in Compromise where you cut a deal with the IRS.
When a request for relief is denied, we routinely file an appeal with the IRS Appeals Division asking for further review of our request for relief. We also routinely ask for a face-to-face hearing with a local Appeals Officer. We have found that a face-to-face hearing is far more productive than a teleconference because we can cover more ground in a face-to-face hearing.
Further, a personal touch lends more credibility to our taxpayer regarding the relief that we are seeking. Unfortunately, the Internal Revenue Manual was recently revised to state that virtually all conferences should be held via telephone and that virtually all face-to-face hearings will no longer be allowed.
The IRS took this step in order to spread the caseload evenly across the United States and to take advantage of technology to reduce costs, especially because the IRS is currently understaffed and is experiencing its own budget woes. There are exceptions to this rule.
Face-to-face appeals are allowed when there are substantial books and records to review, the Appeals Officer cannot judge the credibility of the taxpayer without an in-person conference, the taxpayer has special needs that can only be accommodated with an in-person conference, there are numerous conference participants or the Internal Revenue Manual specifically calls for an in-person conference.
We are firmly against the revised Internal Revenue Manual because we believe that face-to-face appeals are far more productive for our clients in seeking the relief to which they are entitled.
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