SECTION 3. GENERAL SCOPE OF
Internal Revenue Bulletin 2008-48 · 2026-10-03 edition · updated 2026-10-04 · United States
MEDIATION AND ARBITRATION PROCEDURES
The general provisions set forth in Revenue Procedures 2002–44 and 2006–44 apply to the mediation and arbitration, respectively, of OIC and TFRP cases under this two-year pilot program except as specifically stated herein. In accordance with Revenue Procedure 2006–44, arbitration is not available for legal issues.
The mediation and arbitration procedures do not create any special authority for settlement by Appeals. During the mediation and arbitration processes, Appeals is still subject to the procedures that would apply if the issue were being considered via the standard Appeals process, including procedures in the Internal Revenue Manual (IRM), found at http://www.irs.gov/irm/index.html, and other administrative guidance.
December 1, 2008 1224 2008–48 I.R.B.
ria for deviating from national and/or local expense standards.
- For cases with liabilities of $50,000 or more, any settlement or agreement reached through mediation or arbitration must be reviewed by the Office of Chief Counsel pursuant to section 7122(b) before being finalized. When review is required, Appeals will forward the case to Area Counsel for an opinion concerning whether the case is subject to compromise. See IRM sections 5.8.8.5 and 8.23.4.2.2.
Get a plain-English answer with a citation back to this text.
Ask AI about this code