Taxation-Federal Commons^™

Section 1001 (a) of the Internal Revenue Service Restructuring and Reform Act of 1998 (the "1998 Act") required the Commissioner to develop a p lan to ensure the independence of Appeals , including prohibiting ex parte communications between Appeals and other IRS employees to the extent that such communications appear to compromise the independence of Appeals. In our experience, many taxpayers question the independence of an Appeals function that is still part of the IRS. We share the IRS' support for an effective Appeals process, which requires not only that Appeals is independent but also that taxpayers perceive Appeals to …

On behalf of the Section of Taxation (“Section”) of the American Bar Association, the following comments are provided in response to the invitation for public comments issued by the United States Tax Court (the “Court”) with respect to proposed amendments to the Court’s Rules of Practice and Procedure announced on December 20, 2010.1 The proposed amendments include amendments concerning timing for filing summary judgment motions, Rule 1552 computations, motions regarding elections to proceed under the small tax case procedure, answers in lien and levy cases, and recognition of mediation as a form of alternative dispute resolution. These comments have not …