. All of the following statements concerning the taxpayer appeal process are correct, except:

a. The taxpayer may accept the R A R or appeal within the I R S.

b. Appeal within the I R S must always be accompanied by a written protest.

c. Settlement at the I R S appeals level can be based on the hazards of litigation,

d. In certain situations the taxpayer may have the option of having the case heard before the more informal Small Cases Division.