Proposed regs. address IRS Appeals’ review of tax controversies
Treasury and the IRS have proposed regulations (REG-125693-19) to clarify the types of federal tax controversies that may be appealed to the IRS Independent Office of Appeals. These regulations would implement provisions in the Taxpayer First Act (TFA), P.L. 116-25, making access to Appeals generally available and entitling taxpayers to a written explanation in some circumstances when access is denied.