- 21 - their concerns. This legislation requires the agency to establish an independent Office of Appeals--one that may not be influenced by tax collection employees or auditors. Appeals officers will be made available in every state, and they will be better able to work with taxpayers who proceed through the appeals process. 144 Cong. Rec. 14689 (1998) (Statement of Senator Roth). This suggests that Congress intended the Restructuring and Reform Act to result in an Appeals function that acted as something more than just a rubber stamp for the Commissioner’s determinations. The importance of the Appeals process in resolving disputes is also apparent because Congress, as part of the Restructuring and Reform Act, directed respondent to develop alternative dispute resolution procedures. Thus, section 7123(b) now mandates: SEC. 7123(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; * * * Respondent has now developed procedures whereby a taxpayer can request mediation of factual and legal issues after settlement discussions with the Appeals Office have proved unsuccessful. Rev. Proc. 2002-44, 2002-2 C.B. 10; see also Rev. Proc. 2006-44, 2006-44 I.R.B. 800 (establishing arbitration procedures to resolve certain factual disputes).Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NextLast modified: November 10, 2007