26 U.S.C. § 7123: Appeals dispute resolution 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 Independent Office of Appeals. appeals procedures; or unsuccessful attempts to enter into a closing agreement under section 7121 or a compromise under section 7122. appeals procedures; or unsuccessful attempts to enter into a closing agreement under section 7121 or a compromise under section 7122. The Secretary shall prescribe procedures under which an organization which claims to be described in section 501(c) may request an administrative appeal (including a conference relating to such appeal if requested by the organization) to the Internal Revenue Service Independent Office of Appeals of an adverse determination described in paragraph (2). the initial qualification or continuing qualification of the organization as exempt from tax under section 501(a) or as an organization described in section 170(c)(2), the initial classification or continuing classification of the organization as a private foundation under section 509(a), or the initial classification or continuing classification of the organization as a private operating foundation under section 4942(j)(3).