26 U.S. Code § 7123 - Appeals dispute resolution procedures

§ 7123.
Appeals dispute resolution procedures
(a) Early referral to appeals procedures

The Secretary shall prescribe procedures by which any taxpayer may request early referral of 1 or more unresolved issues from the examination or collection division to the Internal Revenue Service Office of Appeals.

(b) Alternative dispute resolution procedures
(1) MediationThe Secretary shall prescribe procedures under which a taxpayer or the Internal Revenue Service Office of Appeals may request non-binding mediation on any issue unresolved at the conclusion of—
(A)
appeals procedures; or
(B)
unsuccessful attempts to enter into a closing agreement under section 7121 or a compromise under section 7122.
(2) ArbitrationThe Secretary shall establish a pilot program under which a taxpayer and the Internal Revenue Service Office of Appeals may jointly request binding arbitration on any issue unresolved at the conclusion of—
(A)
appeals procedures; or
(B)
unsuccessful attempts to enter into a closing agreement under section 7121 or a compromise under section 7122.
Prior Provisions

A prior section 7123 was renumbered section 7124 of this title.

 

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