IRS Proposes Rules For Taxpayers’ Use of Appeals Office (1)

The IRS proposed rules Friday that clarify taxpayers’ right to have their appeals of tax controversies resolved by the agency’s internal appeals office, without litigation.

Under the proposed rules (RIN 1545-BP72) issued Friday, all taxpayers, with certain exceptions, would be able to appeal IRS notices of deficiency against them to the IRS Independent Office of Appeals. The rules would implement parts of Section 7803(e), which was added by the Taxpayer First Act of 2019.

The Independent Office of Appeals attempts to resolve disputes between the IRS and taxpayers via non-court methods, such as conferences and ...