Regulations will provide the exceptions and special rules to the general rule in IRC new section 7803(e)(4) that the appeals resolution process described in new section 7803(e)(3) is generally available to all taxpayers to have a Federal tax controversy referred to the Independent Office of Appeals unless the Secretary of the Treasury has provided an exception. The regulations reflect amendments to the law made by the Taxpayer First Act of 2019 (TFA). The TFA permits these issues to be addressed by regulation.