So IRS appeals is supposed to be an independent body that is neutral and that's designed to resolve disputes with the IRS prior to going to tax collections. In reality Appeals is staffed with a bunch of former auditors and a bunch of former collection agents however we've had a lot of positive experiences in the course of Appeals in this firm so I like dealing with appeals. I find the appeals process is generally fair and impartial and generally yields a pretty good result depending on the circumstances. Now the good news with appeals is that the auditor is not involved in the process at all. The auditor has taken

the time to prepare and submit an audit report which gets forwarded to appeals, but you have the opportunity before the case gets to the appeals officer's desk. In presenting a supplemental submission to counter the auditor's report, essentially you get the last word in the audit before you go and sit down for your Appeals conference. During the day of the Appeals conference, you and the appeals officer or perhaps your representative and the appeals officer will sit down. We'll go through the issues in the audit and try and reach a resolution. The appeals officer will allow you to submit additional documentation but anything that wasn't submitted in the audit is going to have to go to the auditor for review. The appeals officer is not the auditor. The appeals officer is not going to open up the audit but the appeals officer is trying to reach a settlement to avoid the case going into Tax Court. That doesn't mean the appeals officer is going to lie down in the situation but it does mean the appeals officer is willing to take in the risks of litigation and can potentially move the needle in your favor, so in our experience an IRS appeals is a great way to resolve tax issues even after an audit when there's a disagreement.