Comments Regarding Proposed Amendments to the Regulations
Governing Practice Before the Internal Revenue Service
(Title 31, Code of Federal Regulations, Subtitle A, Part 10)
April 23, 2001

Section 10.77  Appeal to Secretary.

Section 10.77 provides that "notice of appeal must include exceptions to the decision of the Administrative Law Judge and supporting reasons for such exceptions." A "notice of appeal" should be a procedural step, not a substantive one. Although supporting reasons for the appeal obviously should be disclosed early in the process, inclusion of such information in a notice of appeal should not be required.