Does the TAS Act Go Far Enough in Protecting the 'Right' to Appeals?

The Taxpayer Assistance and Service Act includes provisions intended to “expand access” to the IRS Independent Office of Appeals, but upon closer examination, its effect on Appeals’ current state is unclear. Skadden attorney Elizabeth Askey discusses whether section 605 of the TAS Act goes far enough in protecting taxpayers’ right to appeal, examining how many exceptions to Appeals consideration are left intact despite the legislation’s stated goal of increasing the office’s independence.