§ 7123. — Appeals dispute resolution procedures.
[Laws in effect as of January 7, 2003]
[Document not affected by Public Laws enacted between
January 7, 2003 and December 19, 2003]
[CITE: 26USC7123]
TITLE 26--INTERNAL REVENUE CODE
Subtitle F--Procedure and Administration
CHAPTER 74--CLOSING AGREEMENTS AND COMPROMISES
Sec. 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) Mediation
The 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) Arbitration
The 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, Sec. 3465(a)(1), July 22, 1998, 112
Stat. 768.)
Prior Provisions
A prior section 7123 was renumbered section 7124 of this title.