The IRS Office of Appeals has addressed estate tax case procedures in accordance with its new "judicial approach and culture (AJAC). One new procedure is a reduction in the number of days remaining on the statute of limitations Appeals will hold the case.
Another feature is that under AJAC, Appeals will not return a case to examinations if the case file is not fully developed factually by exam.
There are only two IRS teams nationwide which handle all E&G appeals, but the staff is dispersed in Chicago, Dallas, Houston, Indianapolis, New York, Philadelphia and Jacksonville, Fla.
Interestingly over 50% of estate and gift tax returns are filed in California.
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