The IRS's Independent Office of Appeals issued internal guidance reminding employees to share a copy of the Appeals case memorandum (ACM) with taxpayers who make an informal request, according to a recent blog post by the National Taxpayer Advocate (NTA).
The internal guidance reiterates what the Internal Revenue Manual (IRM) 8.1.1.6.4(2) has made clear for years, NTA Erin Collins said — that taxpayers may informally request ACMs, and they are not categorically exempt from disclosure.
The ACM is a written analysis in which an Appeals officer details the facts, legal conclusions and rationale behind their proposed resolution. Management must review ACMs before a settlement is final.
The new guidance came in the form of an internal reminder about the existing policy, which does not go as far as Collins’s recommendations that Appeals automatically share ACMs at the close of each case. Learn more.