IRS Issues Proposed Revenue Procedure For Docketing Cases

On October 15, 2015, the IRS issued a proposed revenue procedure (Notice 2015-22)52 that would update Rev. Proc. 87-84, which describes the practices used to manage the flow of docketed cases between the Office of Appeals and the Office of Chief Counsel. The proposed update to Rev. Proc. 87-2453 is not intended to materially modify the current practice of referring docketed cases to Appeals for settlement, but was issued to reflect procedures utilized by the Tax Court in managing the flow of docketed cases between the Office of Appeals ("Appeals") and Office of Chief Counsel, and to ensure that docketed cases are handled consistently nationwide.

The proposed procedures make clear that except for specifically identified exceptions, IRS Counsel will refer all docketed cases to Appeals for settlement consideration. The referral will not be made if Appeals issued the Notice of Deficiency or made the determination that is the basis of the Tax Court's jurisdiction, or if