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Arbitration Procedures for Appeals


  • Cases regarding factual issues that are already in the Appeals administrative process
  • Taxpayer and Appeals must first attempt to negotiate a settlement before requesting arbitration
  • Taxpayer and Appeals may jointly request binding arbitration on unresolved issues

Revenue Procedure 2006-44

Announcement 2008-111


IRM 8.26.6

Page Last Reviewed or Updated: 16-Apr-2014