US IRS Resolution of Tax Controversies

Published on: Jan 20, 2025

On Jan. 15, US IRS issued rules on appeals consideration exceptions.

  • US IRS published final regulations on the resolution of Federal tax controversies.
  • Adds 26 CFR 301.7803-2 and 26 CFR 301.7803-3 to Procedure and Administration Regulations to implement Internal Revenue Code section 7803(e) (26 USC 7803(3)).
  • Rule Summary
  • 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.
Regulators
US IRS
Entity Types
Corp
Reference
90 FR 3645, 1/15/2025; TD 10030; RIN 1545-BP72; Citation: *26 CFR* 301.7803-2, 301.7803-3; 26 USC 7803;
Functions
Accounting; Compliance; Legal; Operations; Reporting; Tax
Countries
United States of America
Category
State
N/A
Products
Corporate
Rule Type
Final
Regions
Am
Rule Date
Jan 15, 2025
Effective Date
Feb 14, 2025
Rule ID
240539
Linked to
N/A
Reg. Last Update
Jan 15, 2025
Report Section
US Investment