The Taxpayer First Act And Practice Before The Independent Office Of Appeals, By Frank Agostino, Esq., Rikki Bassi, J.D., and Andrew Lendrum, Esq.

The Taxpayer First Act of 2019 (“TFA”) established the “Internal Revenue Service Independent Office of Appeals” (sometimes “Appeals” or the “Appeals Office”). Appeals is an independent organization within the Internal Revenue Service (“IRS”) whose “mission is to resolve tax controversies fairly and impartially, without litigation.” The goal of this article is to (a) review how the TFA affects practice before Appeals and (b) suggest best practices for representing taxpayers before the Appeals Office. …

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