P3-U11 · PART 3 · SOURCE CYCLE 2026-2027
IRS Appeals and U.S. Tax Court
Only cards whose complete question and answer were checked against exact primary-authority evidence appear here.
Q1.When may the burden of proof shift to IRS under section 7491?
taxpayer introduces credible evidence on a factual issue taxpayer satisfies substantiation and recordkeeping requirements taxpayer cooperates with reasonable IRS requests qualifying taxpayer meets applicable net-worth limitations special rules apply to penalties and statistical information
Q2.What is the stated mission of the IRS Independent Office of Appeals?
Resolve federal tax controversies without litigation on a fair and impartial basis. Publication 5 states that Appeals resolves federal tax controversies without litigation on a fair and impartial basis.
Q3.A taxpayer disagrees with proposed IRS examination changes and wants administrative review without immediately litigating. Which forum fits Publication 5's mission?
The IRS Independent Office of Appeals. Publication 5 identifies the Independent Office of Appeals as the administrative forum for resolving tax controversies without litigation.
Q4.What threshold rule applies to request for appeals consideration (e.g., preparation, elements contained)?
A request for Appeals consideration must contain the information required for the applicable protest or small-case request.
Q5.How does current authority treat enrolled Agent appearance at appeals conference?
An EA may appear at an IRS Appeals conference when eligible to practice and authorized by the taxpayer.