For as long as the IRS has assessed and collected taxes, the need for conflict resolution and mediation between taxpayers and the examination, compliance, and collection functions of the IRS is charged with this work. This wide range of potential issues includes lien filing, levy action, and asset seizure.
The appeals function bridges the gap between the four operating divisions of the IRS and judiciary review. These operating divisions were created through the IRS Restructuring and Reform Act of 1998:
a) Large and Mid-Size Business (LMSB)
b) Small Business/Self-Employed (SB/SE)
c) Wage and Investment (W&I)
d) Tax-Exempt and Government Entities (TE/GE)
The two most common appeals filed regarding collection and compliance issues are Request for Collection Due Process or Equivalent Hearing and Collection Appeals Request. These are filed in different circumstances and afford taxpayers different rights and resolutions to disputed issues. Understanding which type of appeal is required in a given circumstance is the first step in involving the appeals function.
Majority of the collection and compliance appeals filed are time-sensitive. Knowing how to properly complete and timely file the appropriate appeals is a requirement in participating with the appeals function to conduct a hearing and to formalize a resolution to the disputed issue.