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Published:   |   Last Updated: February 11, 2026

Strengthen Appeals’ Independence and Operational Efficiency:

Preserving and strengthening the independence and operational efficiency of the IRS Independent Office of Appeals is essential to ensuring fair, timely, and effective resolution of tax disputes without unnecessary litigation.

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Objective 15

TAS Recommends

To strengthen taxpayer confidence in the Appeals process and improve case processing efficiency, TAS recommends that the IRS:

Recommendation 8-1

Refocus Appeals Training: Implement mandatory and measurable training programs for Appeals Officers that emphasize a judicial and impartial approach to dispute resolution, thereby reducing compliance-oriented outcomes.

Recommendation 8-2

Clarify Appeals Guidance: Revise the IRM to clearly define policies regarding Appeals Case Memoranda (ACMs). Appeals should either automatically disclose ACMs to taxpayers or discontinue their use if their sole purpose is to document internal settlements without providing feedback to Compliance.

Recommendation 8-3

Broaden Technical Specialist Availability: Require technical guidance coordinators and other specialists advising Appeals Officers to be available in person, upon taxpayer request, to directly address
taxpayers’ unique situations.

Recommendation 8-4

Expand Appeals Transparency: Publish quarterly metrics externally to detail Appeals’ inventory volumes, case resolution timelines, and cycle times to foster transparency and operational accountability.

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