Appeals will not raise new issues and will focus dispute resolution efforts on resolving the points of disagreement identified by the parties. The Appeals process is not a continuation or an extension of the examination process. The discussion of new or additional authorities (e.g. court cases, revenue rulings or revenue procedures) that support a theory or argument previously presented does not constitute consideration of a new issue.
If you submit new information or raise new issues requiring additional analysis, Appeals will generally refer the case to the originating IRS office for consideration of the new information. You will receive the originating office’s comments have an opportunity to respond, and to continue to pursue your appeal rights.
If you are unfamiliar with the Appeals process and your appeal rights, you may be interested in reading the following IRS publications:
- Publication 5, Your Appeal Rights and How to Prepare a Protest if You Disagree,
- Publication 4167, Alternative Dispute Resolution (ADR)
- Publication 4227, Overview of the Appeals Brochure
- Publication 4576, Penalty Appeals
- Notice 1016, How to Stop Interest on Your Account