SECTION 1. PURPOSE AND SCOPE

Section 1001(a) of the Internal Revenue Service Restructuring and Reform Act of 1998, P.L. 105-206, 112 Stat. 685 (RRA 98), states that “The Commissioner of Internal Revenue shall develop and implement a plan to reorganize the Internal Revenue Service. The plan shall . . .

(4) ensure an independent appeals function within the Internal Revenue Service, including the prohibition in the plan of ex parte communications between appeals officers and other Internal Revenue Service employees to the extent that such communications appear to compromise the independence of the appeals officers.” This revenue procedure contains guidance for Service personnel and taxpayers to address the prohibition of ex parte communications between Appeals Officers and other Internal Revenue Service employees that appear to compromise the independence of Appeals Officers. The guidance is in the form of a series of questions and answers that address situations frequently encountered by Appeals Officers during the course of an administrative appeal.