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 .
