# Resolution of Federal Tax Controversies by the Independent Office of Appeals
> **IRS** · Final regulation. · Published 2025-01-15 · Effective 2025-01-15 · 90 FR 3645
## Document
- **Document number:** 2025-00426
- **Category:** tax-irs
- **Sub-agency:** IRS
- **Federal Register citation:** 90 FR 3645
- **CFR reference:** 26 CFR 301
- **Publication date:** 2025-01-15
- **Effective date:** 2025-01-15
- **Treasury docket:** TD 10030
## Abstract

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.

## Source
- [Federal Register document](https://www.federalregister.gov/documents/2025/01/15/2025-00426/resolution-of-federal-tax-controversies-by-the-independent-office-of-appeals)
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