U.S. Code > Title 26 Internal Revenue Code > Subtitle F—Procedure and Administration (§§ 6001—7874) > CHAPTER 74—CLOSING AGREEMENTS AND COMPROMISES (§§ 7121—7124) > § 7123. Appeals dispute resolution procedures

§ 7123. Appeals dispute resolution procedures

(a) Early referral to appeals procedures
The Secretary shall prescribe procedures by which any taxpayer may request early referral of 1 or more unresolved issues from the examination or collection division to the Internal Revenue Service Office of Appeals.
(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; or
(B) unsuccessful attempts to enter into a closing agreement under section 7121 or a compromise under section 7122.
(2) Arbitration
The Secretary shall establish a pilot program under which a taxpayer and the Internal Revenue Service Office of Appeals may jointly request binding arbitration on any issue unresolved at the conclusion of—
(A) appeals procedures; or
(B) unsuccessful attempts to enter into a closing agreement under section 7121 or a compromise under section 7122.