Charles Ruchelman Comments on Proposed IRS Changes Likely to Increase Access to Appeals

House lawmakers are shopping a bill that would broaden Congress's oversight of how taxpayers can appeal their tax disputes with the Internal Revenue Service.

The draft legislation, would provide more opportunities for taxpayers to resolve their cases at a newly named IRS Independent Office of Appeals, but could also create structures that are too formal or rigid, making it more difficult for appeals officers to reach settlements with taxpayers, practitioners told Bloomberg Tax.

“It cuts both ways,” said Charles M. Ruchelman, a member at Caplin & Drysdale, Chartered in Washington. “Seasoned appeals officers can be flexible with procedures. It's not good if they start to feel constrained by statutory or regulatory language.”

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The appeals process has a lot of support from practitioners because it keeps the U.S. Tax Court from being overburdened with cases and it provides an impartial, cost-effective mechanism to reach a compromise, Ruchelman said. It's important that Congress carefully craft the legislation to maintain its independence and functionality, he said.

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Excerpt taken from the article “Proposed IRS Changes Would Likely Increase Access to Appeals” by Laura Davison for Bloomberg Tax’s Daily Tax Report.