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Appeals Alternative Dispute Resolution Programs

Internal Revenue Manual Part 4. Examining Process · 2026-10-03 edition · updated 2026-10-04 · United States

When taxpayers disagree with proposed adjustments, it is beneficial to all parties to resolve disputes at the lowest level possible. IRC 7123 provides for alternative dispute resolution techniques by Appeals. This code section was added by section 3465 of the IRS Reform and Restructuring Act of 1998. Two processes that may expedite dispute resolution are:

Early referral to Appeals

Fast Track Settlement

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▸Contents — Internal Revenue Manual Part 4. Examining Process
Internal Revenue Manual Part 4. Examining Process

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