XBoxBoy: They are required by law to respond within two years and are now flooded with 45,000 appeals. That is exactly why you are in a good negotiating position now if you appeal. I sat in on a hearing, and they took an average of 20 – 30 minutes to hear each case since it is like a courtroom proceedure. They got through about sic in the morning session. Clearly only a tiny percentage get past the stipulation/compromise stage.
In one Florida jurisdiction they also were flooded with appeals, had a two-year time limit, and ended up forced to give each taxpayer appeal exactly what they demanded.