The LTR 380 schedules your conference with the IRS Office of Appeals. This is where your case gets resolved. The Appeals Officer or Settlement Officer will review your position, consider the IRS's position, and work toward a resolution. The conference is typically conducted by phone, though you can request an in-person meeting.
How to Prepare
Review your protest or CDP hearing request. Make sure you can articulate your position clearly and concisely. Gather all supporting documentation and organize it by issue. Anticipate the IRS's counterarguments and prepare responses.
If your case involves a collection alternative (installment agreement, offer in compromise, CNC), have your financial documentation current. The Appeals Officer will want to see a recent Form 433-A with supporting bank statements, pay stubs, and expense documentation.
What to Expect
The Appeals Officer will explain the process, discuss the issues in your case, and ask questions about your position. Appeals conferences are informal compared to court proceedings. The officer has settlement authority and can make concessions that the original IRS function couldn't or wouldn't.
For exam appeals, the officer considers the "hazards of litigation" — the likelihood that the IRS would win or lose in court. For collection appeals (CDP), the officer verifies proper procedures and evaluates your proposed collection alternative.
Rescheduling
If the date doesn't work, call the Appeals Officer promptly to reschedule. Appeals Officers generally accommodate reasonable scheduling requests. Missing the conference without notice can result in the officer issuing a determination based on the file alone, without your input.
If you have an Appeals conference scheduled and want professional representation, call us at (813) 229-7100.