![]() Information for Counsel to prepare for trial and to evaluate the settlement proposal. Information that explains and supports the ATE's basis for settlement.Īny follow up action for Compliance personnel. This IRM supersedes IRM 8.6.2, Appeals Case Memo (ACM) Procedures, dated 08-17-2017, and incorporates Interim Guidance Memorandum AP-08-0720-0012, Uploading all Final Appeals Case Memorandums on ACDS is Mandatory for all Cases, dated July 20, 2020. (3) Made editorial changes to IRM 8.6.2.2.3, paragraphs (4) and (5) to redirect links to current resources. (2) Made editorial changes throughout to update links and correct spelling, punctuation and spacing. This IG makes it mandatory for all Appeals Technical Employees (ATEs), who prepare ACMs, to upload all final ACMs and Forms 5402, Appeals Transmittal and Case Memo, into the Appeals Centralized Database System (ACDS). (1) Incorporated guidance from Interim Guidance AP-08-0720-0012, Uploading all Final Appeals Case Memorandums on ACDS is Mandatory for all Cases, dated July 20, 2020. (1) This transmits revised IRM 8.6.2, Conference and Settlement Practices, Appeals Case Memo (ACM) Procedures. Appeals Case Memo ProceduresĨ.6.2 Appeals Case Memo Procedures Manual Transmittal Conference and Settlement Practices Section 2. 8.6.2.9 Transferring a Case to Counsel's Jurisdiction.8.6.2.8 Settlements that Affect the Taxpayer's Other Years or Related Taxpayers.8.6.2.7 Settlement Computations as Part of the Appeals Case Memo (ACM).8.6.2.6.4.3 Factually or Legally Complicated Issues.8.6.2.6.4.2 Resolved Based on Hazards of Litigation.8.6.2.6.4.1 Unagreed Issues in the Appeals Case Memo (ACM).8.6.2.6.4 "My Evaluation" Section of the Appeals Case Memo (ACM).8.6.2.6.3 "Discussion and Analysis" Section of the Appeals Case Memo (ACM).8.6.2.6.2 "Brief Background" Section of the Appeals Case Memo (ACM).8.6.2.6.1.1 The Issue and Your Recommendation in the Appeals Case Memo (ACM).8.6.2.6.1 "Summary and Recommendation" in the Appeals Case Memo (ACM).8.6.2.4.7 Appeals Case Memo (ACM) Codes.8.6.2.4.3 Tax Period in the Schedule of Adjustments.8.6.2.4.2 Listing the Issues in the Case.8.6.2.4.1 Issue Numbers in the Schedule of Adjustments.8.6.2.4 Preparing a Schedule of Adjustments. ![]() 8.6.2.3.5 5402 and ACM Case Closing Procedures.8.6.2.3.4 Routing Form 5402 and ACM Feedback to LB&I for Non-ATCL Cases.8.6.2.3.2 Using Form 5402 as the Appeals Case Memo (ACM).8.6.2.3.1 Accessing the Customized Form 5402.8.6.2.2.4 Writing Style in Appeals Case Memos (ACM) and ACM Attachments.8.6.2.2.3 Introduction to "Plain Language" Writing.8.6.2.2.2 Types of Appeals Case Memos (ACMs). ![]() ![]()
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