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TREAS/IRS RIN: 1545-BP72 Publication ID: Spring 2021 
Title: Appeals Resolution of Certain Federal Tax Controversies Without Litigation 

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.

Agency: Department of the Treasury(TREAS)  Priority: Substantive, Nonsignificant 
RIN Status: Previously published in the Unified Agenda Agenda Stage of Rulemaking: Proposed Rule Stage 
Major: No  Unfunded Mandates: No 
CFR Citation: Not Yet Determined     (To search for a specific CFR, visit the Code of Federal Regulations.)
Legal Authority: 26 U.S.C. 7805    26 U.S.C. 7803   
Legal Deadline:  None
Action Date FR Cite
NPRM  12/00/2021 
Additional Information: REG-125693-19 (NPRM) Drafter attorney: Keith Brau (202) 317-5426 Reviewer attorney: Tom Curteman (202) 317-5422 Treasury attorney: N/A CC:PA:B5
Regulatory Flexibility Analysis Required: No  Government Levels Affected: None 
Federalism: No 
Included in the Regulatory Plan: No 
RIN Data Printed in the FR: No 
Agency Contact:
Keith L. Brau
Department of the Treasury
Internal Revenue Service
1111 Constitution Avenue NW.,
Washington, DC 20224
Phone:202 317-5426