One often overlooked taxpayer right is his or her right to their full administrative case file prior to an IRS Appeals hearing. This is a legal requirement and is codified in IRC § 7803(e)(7). However, the taxpayer must affirmatively request the file. And while the Appeals Officer may try and limit access to the information disclosed, taxpayers are well advised to request specific documents related to their file — like, the Revenue Officer’s internal case notes and call logs. The administrative case file must be delivered to the taxpayer not later than 10 days before the conference.