Final regulations on Appeals process, IRS Fast Track Settlement pilot programs

Treasury and the IRS on January 14 issued final regulations affecting taxpayers requesting the consideration of federal tax controversies by the IRS Independent Office of Appeals (Appeals). The guidance implements the Taxpayer First Act of 2019 that codified Appeals and made the office generally available to taxpayers. The guidance provides that although the Appeals resolution process generally is available to all taxpayers, there are several significant exceptions to consideration by Appeals. The final regulations also address certain procedural and timing rules that must be met before Appeals consideration is available. The final regulations, which are effective January 15, adopt, with slight modifications in response to comments, proposed regulations issued in September 2022.
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