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IRS Tax Dispute Resolution

Alternative Dispute Resolution

RRA98, Section 3465, Alternative Dispute Resolution Procedures - Section 3465 of the IRS Restructuring and Reform Act of 1998 provides for the addition of new Internal Revenue Code Section 7123, which calls for the establishment of procedures regarding alternative dispute resolution. The IRS supports the development and use of alternative dispute resolution techniques by Appeals to create an administrative forum, independent of compliance functions, to efficiently prevent or resolve disputes.

  • Arbitration - Announcement 2002-60, 2002-26 IRB 28 - Test of arbitration procedure for Appeals. This announcement extends the test of the arbitration procedures set forth in Announcement 2000-4, 2000-1 C.B. 317, for an additional one-year period.
  • Arbitration - Announcement 2000-4,2000-3 IRB 317 - IRB 2000-3 Pursuant to section 7123(b)(2) of the Code, Appeals is conducting a 2-year test of a binding arbitration procedure. This announcement contains procedures that taxpayers may use to request binding arbitration for factual issues that are already in the Appeals administrative process and which are not docketed in any court.
  • Early Referral Request - Rev. Proc 99-28, 1999-29 IRB 109 - The IRS has issued guidance describing the method by which a taxpayer may request an early referral of one or more unresolved issues from the Examination or Collection Division to the Office of Appeals.
  • Mediation - Rev. Proc.2002-44, 2002-26 IRB 10 - Appeals mediation procedure. - This document formally establishes the Appeals mediation procedure and modifies and expands the availability of mediation for cases that are already in the Appeals administrative process.
  • Simultaneous Appeals/Competent Authority Revenue Procedure 2002-52, 2002-31 IRB 242 - The simultaneous Appeals/competent authority procedure encourages taxpayers to request competent authority assistance and the participation of Appeals while a case is under the Examination Division's jurisdiction. Revenue Procedure 2002-52 contains the competent jurisdiction. Revenue Procedure 2002-52 contains the competent authority procedures. Section 8 of Rev. Proc 2002-52 specifies the circumstances under which the simultaneous appeals/competent authority procedure may be requested and describes the role of Appeals.
  • Tax Exempt Bonds - Rev. Proc.99-35, 1999-41 IRB 501 - The IRS has provided procedures for bond issuers to request an administrative appeal of a proposed adverse determination by a Employee Plans/Exempt Organizations Key District that the interest on their bonds is not excludable from gross income under Code Sec. 103.
  • Delegation Order 236 (Rev.3) - Settlement Offers and Closing Agreements in Coordinated Examination Program Cases Where Appeals has Effected a Settlement.
  • Delegation Order 247 - Delegation Order 247 Authority of Examination case managers to Accept Settlement Offers and Execute Agreements on Industry Specialization (ISP) and International Field Assistance Specialization Program (IFASP) Issues is a new examination tool which can be used to settle appropriate issues at the case manager level.
  • Rev. Proc.96-15, 1996-3 IRB 41 - Valuing artwork is important for such tax purposes as estate and gift taxes and the charitable contribution deduction. Rev. Proc. 96-15, 1996-3 IRB 41, tells taxpayers how to obtain an IRS review of their art-work valuations before filing returns.
  • Fast Track Mediation - IRS offers a new service designed to expedite case resolution on disputes that arise from examination or collection actions.
  • LMSB Fast Track Dispute Resolution - This LMSB/Appeals program is designed to utilize the mediation skills and delegated settlement authority of Appeals to resolve issues while the case and issues remain under the jurisdiction and control of the LMSB examination function. Appeals performs as a facilitator to arrive at, and execute a resolution/settlement which is mutually agreed upon by both the taxpayer and the LMSB team manager. More detailed information can be found in Notice 2001-67 .
  • Fast Track Agreement Form - LMSB Fast Track Dispute Resolution Pilot program is discussed in the January-February edition of The Tax Executive Magazine .
  • Form 8821 , Tax Information Authorization
  • News Release - IRS Wants to Reduce the Time for Large Corporate Appeals - Mutually accelerated appeals process.

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