Better Documentation Is Needed to Support Office of Appeals’ Decisions on International Cases

The Chief, Appeals, should reinforce to Appeals personnel that ACMs for cases settled under the hazards of litigation should be documented to include the weighted hazards of both the taxpayer's and the Government's positions and show how settlement amounts or percentages were determined, as required by IRS guidance.

The Chief, Appeals, in coordination with other IRS offices involved in the storage of Appeals case files, should attempt to secure the unlocated case files, determine the reason(s) the files were not locatable, and implement controls to ensure accessibility of case files.