Data / Federal rules / 2025-00426
Resolution of Federal Tax Controversies by the Independent Office of Appeals
The Internal Revenue Service published this final rule in the Federal Register on January 15, 2025. It took effect on January 15, 2025.
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What the agency says
This document contains final regulations that provide guidance on the resolution of Federal tax controversies by the IRS Independent Office of Appeals (Appeals) under the Taxpayer First Act of 2019 (TFA). The final regulations provide that while the Appeals resolution process is generally available to all taxpayers to resolve Federal tax controversies, there are certain 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 regulations affect taxpayers requesting Appeals consideration of Federal tax controversies.
Key facts
- Document number
- 2025-00426
- Type
- Final rule
- Action
- Final regulation
- Agency
- Treasury Department; Internal Revenue Service
- Published
- January 15, 2025
- Takes effect
- January 15, 2025
- Dates
- Effective date: These regulations are effective on January 15, 2025.
- Docket
- TD 10030
- Regulation ID (RIN)
- 1545-BP72
- Code of Federal Regulations
- 26 CFR 301
- Topics
- Employment taxes; Estate taxes; Excise taxes; Gift taxes; Income taxes; Penalties; Reporting and recordkeeping requirements
- Pages
- 21
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Everything from the Internal Revenue Service · Rules on employment taxes · Rules on estate taxes · Rules on excise taxes · Published in January 2025
Read from the Federal Register API, last updated 2026-10-23. The document on federalregister.gov is the official record; dates and dockets can change through later corrections. Free to reuse with credit to SpecStream under CC BY 4.0.