In an IRS examination, the facts are fixed and do not change often, whereas a collection appeal the financial information of the taxpayer is being constantly updated. This means that if something were to change involving the financial position of a taxpayer in a collection appeal, it would change the case completely.
An example of this could be a situation where the taxpayer receives an inheritance after they have filed for a collection appeal, which may eliminate their ability to successfully obtain an offer in compromise. Other situations that could arise are a change in employment, a raise in their pay, a reduction in their expenses and things of this nature. It is important for a taxpayer to understand that all of these changes will affect their collection appeal process.
In an examination, the financial information will be fixed and therefore changes in the taxpayer’s financial situation will not change the outcome of the examination. The IRS is just examining the information it has for a certain stretch of time and therefore new information would not likely change their opinion of things that happened in the past.