Appeals Process

[ILLMAS]

Wondering if someone here has some experience with the appeals process. TP did not agree with the IRS changes for 2006 so the case was referred to appeals, a couple of months later a new agents sends out an IDR to examine 2007 & 2008, I am wondering if this is a normal process, when 2006 has not been resolved? Also if you can point to me to some reference material, I would really apprecaited, I am doing research for my associated.

Thanks

MAS

[rfassett]

MAS, I subscribe to www.beyond415.com. Check it out. It has some good info there. As to the correlation between 2007 & 8 and 2006, if the IRS found issues that warrented broadening the scope, they certainly could look at the succeeding years, I have one a couple years ago that did that. And another one that was a no change that the only reason the scope was not broadened was because the field auditor squashed it. He realized he had wasted his time on the first one and did not want to do it on the second. The dif score kicked out both, but when the auditor determined the first was solid, he opted not to look at the second.

[jainen]

>>a couple of months later a new agents sends out an IDR to examine 2007 & 2008<<

Yeah,it seems like a cheap shot. But why did they take it? Hopefully they just want to pressure the taxpayer into a settlement, "months" being longer than scheduled. Or maybe his appeal generated a better look at the guy, whereupon they decided he deserves an even more better look! I recommend you call 'em up and ask what's going on.

[ILLMAS]

I think we are screwed, just notice the IDR was dated back in early 2012, the prior agent never gave us a copy, TP never received a copy nor did she ever requested information for 2007 & 2008. We dealt most of 2011 and 2012 dealing with 2006 issues, we didn't agree with the changes, requested to be sent to appeals and now we get this. This is very shady on their part, the IDR is almost a year old, and it was sent to us barely last week.

[Max W]

It is standard practice with the IRS to do audits for 2 or 3 years at a time.

I just finished one for 3 year which were all handled together.

The last 2 years may still be open, otherwise a determination letter would have gone out.

Even if an audit is closed, it can be reopened with an audit reconsideration.

The fact that a different examiner was assigned to the last 2 years means nothing. The assignment comes from the manager and the other examiner could be retired, dead, moved to another office or have too much of a work load.