Part 8. Appeals
Table of Contents
- 8.1 Appeals Function
- 8.2 Pre 90-Day and 90-Day Cases
- 8.4 Appeals Docketed Cases
- 8.6 Conference and Settlement Practices
- 8.7
Technical and Procedural Guidelines
- 8.7.1 Guidelines for Cases with Special Issues
- 8.7.3 Domestic and International Operations Programs
- 8.7.4 Appeals Estate and Gift Tax Cases
- 8.7.5 Transferee and Transferor Liabilities
- 8.7.6 Appeals Bankruptcy Cases
- 8.7.7 Claim and Overassessment Cases
- 8.7.8 Tax Exempt and Government Entities (TE/GE) Cases
- 8.7.9 Joint Committee (JC) Cases
- 8.7.10 Excise Tax Cases and IRA Adjustments
- 8.7.11 Working Appeals Team Cases
- 8.7.13 e-file Cases
- 8.7.14 Freedom of Information Act (FOIA) Administrative Appeal Cases
- 8.7.15 Administrative Cost and Qualified Offer Cases
- 8.7.16 Appeals Employment Tax Procedures
- 8.10
Appeals Reports and Projects
- 8.10.1 Internal Reports
- 8.10.2 Reports to Outside Officials
- 8.10.3 Appeals Inventory Validation Process
- 8.11
Penalties Worked in Appeals
- 8.11.1 Return Related Penalties in Appeals
- 8.11.3 Return Preparer Penalty Cases
- 8.11.4 Penalty Appeals (PENAP)
- 8.11.5 International Penalties
- 8.11.6 FBAR Penalties
- 8.11.7 Abusive Transaction Penalties
- 8.11.8 Miscellaneous Penalties
- 8.13 Closing Agreements
- 8.17 Settlement Computations and Statutory Notices of Deficiency
- 8.18 Valuation Assistance
- 8.19
Appeals Pass-Through Entity Handbook
- 8.19.1 Procedures and Authorities
- 8.19.2 Managers/TEFRA Coordinators
- 8.19.3 Guidance for Appeals Officers
- 8.19.4 Responsibilities of Appeals Tax Computation Specialists
- 8.19.5 Account and Processing Support
- 8.19.6 Investor Cases
- 8.19.7 Administrative Adjustment Request
- 8.19.8 Collection Cases
- 8.19.9 Non-TEFRA Procedures
- 8.20
Appeals Case Processing Manual
- 8.20.2 IDRS Transcripts and Automated Systems
- 8.20.3 Appeals Centralized Database System (ACDS)
- 8.20.5 Processing and Establishing New Receipts
- 8.20.6 Interim Actions - Remittances, Partials, Transfers, and Returns
- 8.20.7 General Closing Procedures
- 8.20.10 Appeals Processing Employee Automated System (PEAs)
- 8.21
Appeals Statute Responsibility
- 8.21.1 General Statute Responsibility
- 8.21.2 Account and Processing Support (APS) Statute Responsibility
- 8.21.3 Appeals Technical Employees Statute Responsibility
- 8.21.4 Appeals Management Statute Responsibility
- 8.21.5 Collection Statutes
- 8.21.6 Statute Information on TEFRA Cases
- 8.21.7 Barred Statute Procedures
- 8.22
Collection Due Process
- 8.22.1 Front-End and Interim Processing of Collection Due Process and Equivalent Hearing Cases
- 8.22.3 Back-End Processing for Collection Due Process and Equivalent Hearing Cases
- 8.22.4 Collection Due Process Appeals Program
- 8.22.5 Receipt, Control and Pre-Conference Considerations
- 8.22.6 Cases Requiring Special Handling
- 8.22.7 Alternatives to Collection Action
- 8.22.8 Liability Issues and Relief from Liability
- 8.22.9 Closing and Post Closing Actions
- 8.23
Offer in Compromise
- 8.23.1 Offer in Compromise Overview
- 8.23.2 Receipt and Control of Non-Collection Due Process (CDP) Offers
- 8.23.3 Evaluation of Offers in Compromise
- 8.23.4 Acceptance, Rejection Sustention, and Withdrawal Procedures for Non-Collection Due Process (CDP) Offers
- 8.23.6 OIC Processing and Closing Procedures
- 8.24
Collection Appeals Program and Jeopardy Levy Appeals
- 8.24.1 Collection Appeals Program (CAP)
- 8.24.2 Jeopardy Levy Appeals
- 8.25 Trust Fund Recovery Penalty (TFRP)
- 8.26
Alternative Dispute Resolution (ADR) Program
- 8.26.1 Fast Track Settlement for Large Business and International (LB&I) Taxpayers
- 8.26.2 Fast Track Settlement for Small Business/Self Employed (SB/SE) Taxpayers
- 8.26.3 Small Business Self Employed (SB/SE) Fast Track Mediation
- 8.26.4 Early Referral Procedures
- 8.26.5 Post Appeals Mediation (PAM) Procedures for Non-Collection Cases
- 8.26.6 Appeals Arbitration Procedures (Non-Collection Cases)
- 8.26.8 Compliance Assurance Process - Fast Track Settlement
- 8.26.9 Offer in Compromise Mediation Procedures
- 8.26.10 Trust Fund Recovery Penalty Mediation Procedures