Of the roughly one hundred thousand cases a year that go before the Internal Revenue Service Appeals Division, more than 80 percent get resolved without going to litigation. That by itself is a good reason for tax professionals to utilize the appeals process, according to Sarah Ingram, chief at the IRS Appeals unit."We see large taxpayers, small taxpayers, individuals. We see large-dollar figures, any topic under the sun," she said. "Almost half of those cases come from the Collection Division, including either collection due process or offers-in-compromise kinds of activities."

The 7,000 members of the Tax Executives Institute have had successful experiences with their interaction with Appeals, said Eli J. Dicker, chief tax counsel at the institute. "They recognize that Appeals is a key step, almost the last step, in the administrative examination process, and reflects the last clear chance before they have to make a judgment: Do they write a check to the IRS or do they write a check heading to the court house? And by and large, they have had satisfactory experiences," he said.

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