I do believe that if a taxpayer presses an issue and takes it up through the system, and if that taxpayer is right, he or she will ultimately prevail. It's just that the process is costly in terms of fees, time and aggravation. It is important for the IRS to avoid procedural shortcuts and treat the taxpayers fairly up front, so that mistakes are not made and taxpayers are not put in the position of choosing whether to pay the wrong amount of tax or pay for assistance to fight it out. Either way the taxpayer loses. As an organization, the IRS has excellent technical resources which it does not use to its best advantage.
Tax collection is a complex process given the number of applicable federal and state statutes.
Revenue officers can be expected to require assistance in some cases. The Special Procedures function is designed to provide technical assistance to the tax collectors in the field, and in those districts where it is given the staffing and finding it needs, it has proven to be very valuable. However, each district is given the discretion to determine how its own Special Procedures will be staffed and how it will operate. In some districts, Special Procedures is underachieving because the advisors have little experience and little support. Some districts view Special Procedures as a dumping ground for revenue officers and even managers who have had problems elsewhere.