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referred to us. Procedures for making audio recordings
are described in Notice 89-51, 1989-1 C.B., and Appeals
employees will follow the provisions of Notice 89-51
when allowing recordings in cases within Appeals
jurisdiction. [Emphasis added.]
In fact, Appeals officers from time to time have performed
limited audit functions when necessary to expediently resolve tax
cases. Further, in recent years, both Congress and the Service
have increasingly utilized Appeals officers and settlement
officers during the examination and collection phases of a tax
case. See, e.g., secs. 6320, 6330, 7123; see also Rev. Proc.
2003-41, 2003-25 I.R.B. 1047 (fast-track mediation procedures);
Rev. Proc. 2003-40, 2003-25 I.R.B. 1044 (fast-track settlement
procedures); Announcement 2003-36, 2003-25 I.R.B. 1093 (tax-
exempt bond mediation program); Rev. Proc. 2002-67, 2002-43
I.R.B. 733 (tax shelter settlement initiative); Rev. Proc. 2002-
52, 2002-31 I.R.B. 242 (simultaneous Appeals consideration and
competent authority assistance procedure); I.R.S. News Release
IR-2000-42 (June 27, 2000) (Mutually Accelerated Appeals Process
for coordinated examinations of large corporate taxpayers); Rev.
Proc. 99-28, 1999-2 C.B. 109 (procedures for early referral of
“unresolved issues from the Examination or Collection Division to
the Office of Appeals”). Given this involvement of Appeals in
the Examination, Employee Plans and Exempt Organizations, and
Collection functions, section 7521 cannot logically be
interpreted as properly excluding the Appeals Office simply
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