SECTION 2. BACKGROUND

Section 7123(b)(1) of the Internal Revenue Code, as enacted by section 3465 of the Internal Revenue Service Restructuring and Reform Act of 1998, Pub. L. No. 105–206, 112 Stat. 685, provides the statutory authority for the Appeals mediation program. On July 1, 2002, Revenue Procedure 2002–44, 2002–2 C.B. 10, formally established the Appeals mediation procedure. Rev. Proc. 2002–44 modified and expanded the availability of mediation for

cases that are already in the Appeals administrative process. This revenue procedure supersedes Rev. Proc. 2002–44.