Monthly Archives: October 2014

Treasury Department Circular 230 Disclaimer Eliminated Form 2848 Incorporates Circular 230

Practitioners should remove any reference to a Circular 230 or IRS requirement in disclaimers sent with any written correspondence.  The IRS Office of Professional Responsibility (OPR) may issue letters to practitioners if they continue to use the disclaimer on their emails.[1]  A brief explanation follows.

New IRS Appeals Procedures Complicate Tax Dispute Resolution

This article describes and evaluates the new IRS Appeals Office policy for handling IRS audit appeals. This new policy is known as the Appeals Judicial Approach and Culture (“AJAC”) Project. The stated goals of the AJAC Project are (1) to return Appeals to a “quasi-judicial approach” in the way it handles cases; and (2) to enhance perceptions that the IRS Appeals Office is fair, impartial and independent.[1] The AJAC Project applies to IRS appeals filed after September 2, 2014.[2] Practitioners who fail to understand and support the new dispute resolution process under the AJAC Project may cause their clients unnecessary and sometimes expensive delay on top of the already delayed dispute resolution process. In egregious cases, the taxpayer’s failure to follow the AJAC Project guidelines can result in the denial of the taxpayer’s appeal.