For anyone who practices tax lit in the US Tax Court, what’s your experience with the independent office of appeals? They don’t seem quite that “independent” to me and so far, I’ve only had one appeals officer who seemed knowledgeable and nice. It’s been a real headache. Interested to hear other people’s experience.

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They are independent and your best shot at a reasonable resolution. Like everything else, outcome will be influenced heavily based on who you get. — former TC clerk & OCC

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Thank you for your insight!

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They are independent. But they don’t always do their homework in advance of the Appeals conference. Agree with A1 that it depends on which AO you’re assigned

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Very interesting. At this point, it might make sense to wait for Chief Counsel and have another bite at the apple. You could always complain to the Appeals Team Manager once you’re out of the Appeals woods (or perhaps before too).

Hang in there. There are some really good appeals officers. You’ll come across bad apples, of course, like anywhere. But if you ever have a case where they are clearly not acting independently, you can request a call with their manager. I have had an appeals officer switched out where, before even reviewing my appeal, he said my argument was “stupid.” I went on to get a great result with another AO.

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