Section 1001 (a) of the Internal Revenue Service Restructuring and Reform Act of 1998 (the "1998 Act") required the Commissioner to develop a p lan to ensure the independence of Appeals , including prohibiting ex parte communications between Appeals and other IRS employees to the extent that such communications appear to compromise the independence of Appeals. In our experience, many taxpayers question the independence of an Appeals function that is still part of the IRS. We share the IRS' support for an effective Appeals process, which requires not only that Appeals is independent but also that taxpayers perceive Appeals to be truly independent , and we believe that the prohibition of ex parte communications contributes significantly to that goal. We commend the IRS for the time and thought that has been put into preparing the proposed Revenue Procedure to promote the independence and perceived independence of Appeals. We also appreciate the opportunity to comment on the proposal and hope that our comments prove to be helpful. We agree with the proposal for the most part and believe that it represents a significant improvement to Revenue Procedure 2000-43. We respectfully suggest, however, the IRS consider certain changes that we believe could further improve the procedures