15 Jan 2025

💼IRS Appeals Regulations for Resolving Federal Tax Controversies

Resolution of Federal Tax Controversies by the Independent Office of Appeals

Summary

This document contains final regulations that provide guidance on the resolution of Federal tax controversies by the IRS Independent Office of Appeals (Appeals) under the Taxpayer First Act of 2019 (TFA). The final regulations provide that while the Appeals resolution process is generally available to all taxpayers to resolve Federal tax controversies, there are certain exceptions to consideration by Appeals. The final regulations also address certain procedural and timing rules that must be met before Appeals consideration is available. The regulations affect taxpayers requesting Appeals consideration of Federal tax controversies.

Agencies

  • Treasury Department
  • Internal Revenue Service

Business Impact ?

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The regulations affect taxpayers seeking to resolve federal tax controversies through the IRS Appeals process, establishing compliance requirements and potential financial implications for businesses dealing with tax disputes. Specifically, exceptions to consideration by Appeals could impact how taxpayers navigate their rights, affecting their financial and operational strategies.

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