Some Georgia residents and companies have tax problems that lead to enforcement actions by the Internal Revenue Service. When they do, they are able to go through the IRS’s appeals process. Cases that are complex and that involve large amounts of money have traditionally been handled by 35 appeals team case leaders, or ACTLs. The IRS is considering taking their settlement authority away and turning it over to their managers instead.
Shifting the authority away from the ACTLs could potentially weaken the appeals process while making it take much longer. The IRS has stated that it is concerned about settlements that it believes are bad or inconsistent as well as about ACTLs that are rogue in their decisions.
Most large cases are handled by teams of four to five ACTLs, meaning that there is little opportunity for one ACTL to act in the manner that the IRS has said causes its concerns. If ACTLs have to take settlement agreements to their managers for approval, a bottleneck could occur. The managers do not sit in on the cases and would need to take the time to get to know the cases, which often are highly complex.
Georgia residents who have received notices of tax liens or levies are able to appeal the IRS’s findings, but it’s important to act quickly. The appeals process may help people to resolve their tax matters and potentially reduce any assessed penalties. A tax law attorney may be able to help the client with negotiating a resolution that is beneficial for the client while also ending the tax controversy.