Forbes: Earlier this week, the IRS announced the end of its Appeals Arbitration Program. The program, which was authorized by Section 7123(b), was designed to allow the taxpayer and the Service to jointly request binding arbitration on any unresolved issue that remained at the conclusion of the appeals procedure or after attempting a closing agreement or compromise.
Revenue Procedure 2006-44 formally established the program (after a series of test years). The program’s purpose was to “improve tax administration, provide customer service and reduce taxpayer burden.” The program was designed for those cases that “a limited number of factual issues remain unresolved following settlement discussions in Appeals.” The arbitration program was limited to fact issues, and legal issues were specifically excluded from the scope of the program.
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