SECTION 2. BACKGROUND

In 1927, the Internal Revenue Service established an administrative appeal process to resolve tax disputes without litigation. Local appeals offices have traditionally been separate from the IRS office that proposed the adjustment. However, section 1001(a)(4) of RRA 98 requires the IRS, as part of its reorganization plan, to establish an independent Office of Appeals — one that may not be influenced by tax collection or examination employees through ex parte communications with Appeals Officers that appear to compromise the independence of Appeals Officers.