In 2019, the Taxpayer First Act established the IRS Independent Office of Appeals (IOA) to resolve federal tax “controversies” without litigation. In general, the IOA’s resolution process is available to all taxpayers, but the IOA isn’t required to consider every dispute. Now, the IRS is proposing regulations to clarify what rules the IOA must follow when denying a request for a resolution. Along with other guidelines, the proposed regs say the IOA must be fair and impartial to both the government and taxpayer, promote a consistent interpretation of tax laws and enhance public confidence in the process. Comments on the proposed regs are due by Nov. 12, 2022.
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