26 U.S.C. § 7123 — Appeals dispute resolution procedures
submitted 28 years ago by Pub. L. 105-206 to r/title-26-INTERNAL-REVENUE-CODE · 311 words · no verdicts yet
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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 Independent Office of Appeals.
The Secretary shall prescribe procedures under which a taxpayer or the Internal Revenue Service Independent Office of Appeals may request non-binding mediation on any issue unresolved at the conclusion of—
appeals procedures; or
unsuccessful attempts to enter into a closing agreement under section 7121 or a compromise under section 7122.
The Secretary shall establish a pilot program under which a taxpayer and the Internal Revenue Service Independent Office of Appeals may jointly request binding arbitration on any issue unresolved at the conclusion of—
appeals procedures; or
unsuccessful attempts to enter into a closing agreement under section 7121 or a compromise under section 7122.
The Secretary shall prescribe procedures under which an organization which claims to be described in section 501(c) may request an administrative appeal (including a conference relating to such appeal if requested by the organization) to the Internal Revenue Service Independent Office of Appeals of an adverse determination described in paragraph (2).
For purposes of paragraph (1), an adverse determination is described in this paragraph if such determination is adverse to an organization with respect to—
the initial qualification or continuing qualification of the organization as exempt from tax under section 501(a) or as an organization described in section 170(c)(2),
the initial classification or continuing classification of the organization as a private foundation* under section 509(a), or
the initial classification or continuing classification of the organization as a private operating foundation under section 4942(j)(3).
Source credit: (Added Pub. L. 105–206, title III, § 3465(a)(1), July 22, 1998, 112 Stat. 768; amended Pub. L. 114–113, div. Q, title IV, § 404(a), Dec. 18, 2015, 129 Stat. 3118; Pub. L. 116–25, title I, § 1001(b)(1)(G), July 1, 2019, 133 Stat. 985.)
- 1998Enacted · Pub. L. 105-206 · 112 Stat. 768
- 2015Amended · Pub. L. 114-113 · 129 Stat. 3118
- 2019Amended · Pub. L. 116-25 · 133 Stat. 985
A history note hasn’t been published yet. The record shows enactment by Pub. L. 105-206 on 1998-07-22.
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