Today, in Revenue Procedure 2012-18, the Internal Revenue Service updated its rules dictating how the Office of Appeals is allowed to communicate with other IRS sections or divisions, when a taxpayer or the their representative is not present.
Since the issuance of Rev. Proc. 2000-43 in October 2000, which established the rules for this type of communication, the IRS has made changes to some of its business practices and adopted new policies and procedures that did not exist at the time that the Rev. Proc. 2000-43 was issued. The updated rules, specifically address communications between the Office of Appeals and other IRS employees that occur without the taxpayer or the taxpayer's representative being present.
In a news release, the IRS stated:
The new rules implement a provision in the IRS Restructuring and Reform Act of 1998, aimed at ensuring that the Office of Appeals remains an independent vehicle for settling audit and collection-related disputes between taxpayers and the IRS. As part of the IRS, but operating independently from the agency's compliance functions, the Appeals office is supposed to serve as one of the checks and balances in the U.S. system of tax administration.
To read Revenue Procedure 2012-18, click here.