The US Treasury Department and Internal Revenue Service (IRS) have issued final regulations (T.D. 10030) that offer detailed guidance on resolving federal tax disputes through the IRS Independent Office of Appeals in accordance with the Taxpayer First Act of 2019.
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.
The final regulations apply to all Appeals requests received 30 days after their publication in the Federal Register, which is scheduled for 15 January 2025.
