Re resolution of Federal tax controversies by Independent Office of Appeals (Appeals).
While the Appeals resolution process is generally available to all taxpayers to resolve Federal tax controversies, there are certain exceptions to consideration by Appeals.
Address procedural, timing rules that must be met before consideration is available.
Affect taxpayers requesting Appeals consideration of Federal tax controversies.
Effectiveness
Rules effective Jan. 15, 2025; apply to requests received on or after Feb. 14, 2025.