Daily Tax Update - March 23, 2016: IRS Issues Guidance on Administrative Appeals Process

IRS Issues Guidance on Administrative Appeals Process:  Today, the IRS issued Revenue Procedure 2016-22 to clarify and describe the practices for the administrative appeals process in cases docketed in the US Tax Court.  The guidance, which updates Rev. Proc. 87-24, is intended to facilitate effective utilization of administrative appeals and achieve earlier development and disposition of Tax Court cases.  The Revenue Procedure states that the Office of Chief Counsel (Counsel) will refer docketed cases to the Office of Appeals (Appeals) for settlement consideration unless either: (1) Appeals issued the notice of deficiency or made the determination that is the basis for the Tax Court’s jurisdiction; or (2) the taxpayer notifies Counsel that the taxpayer wants to forego settlement consideration by Appeals.  When a docketed case is forwarded to Appeals for consideration, Appeals has the sole authority to resolve the case through settlement until the case is returned to Counsel.


Sixth Court Requires IRS to Identify Applicants for Tax-Exempt Status, Even if Application Not Granted:  For a more detailed analysis of yesterday's US Court of Appeals for the Sixth Circuit holding requiring the IRS to identify applicants for tax-exempt status, even if the application was not granted, click here.