This letter is used by the IRS Independent Office of Appeals (Appeals) as an acknowledgement and conference letter based on your appeal of an IRS determination. It may include information about how to schedule a conference, case specific information, provide a preliminary review summary, identify items to provide in advance to Appeals and provide information on obtaining representation.
Appeals will not raise new issues and will focus dispute resolution efforts on resolving the points of disagreement identified by the parties. The Appeals process is not a continuation or an extension of the examination process. The discussion of new or additional authorities (e.g. court cases, revenue rulings or revenue procedures) that support a theory or argument previously presented does not constitute consideration of a new issue.
If you submit new information or raise new issues requiring additional analysis, Appeals will generally refer the case to the originating IRS office for consideration of the new information. You will receive the originating office’s comments have an opportunity to respond, and to continue to pursue your appeal rights.
If you are unfamiliar with the Appeals process and your appeal rights, you may be interested in reading the following IRS publications:
This notice or letter may include additional topics that have not yet been covered here. Please check back frequently for updates.