2003 U.S. Code
Title 26 - INTERNAL REVENUE CODE
CHAPTER 74 - CLOSING AGREEMENTS AND COMPROMISES
Sec. 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.
(Added Pub. L. 105–206, title III, §3465(a)(1), July 22, 1998, 112 Stat. 768.)
Prior ProvisionsA prior section 7123 was renumbered section 7124 of this title.