Appeals is often referred to as the "candy store" within IRS circles. Appeals officers can grant concessions on an audit or a payment plan that a regular IRS employee, either can't or won't make. While auditors (Revenue Agents) or collections (Revenue Officers) have a more rigid set of rules to live by, appeals officers are allowed greater leeway, often referred to as the hazards of litigation. The appeal process is a required step if the taxpayer wants to sue the IRS or take a tax issue to court. Certain steps must be taken to get into appeals but the IRS must explain your rights to appeals any time it rejects your payment proposal, including an Offer in Compromise, and before assessing a tax resulting from an audit.