# § 7123. Appeals dispute resolution procedures
**(a)** **Early referral to appeals 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.
**(b)** **Alternative dispute resolution procedures**
**(1)** **Mediation** The Secretary shall prescribe procedures under which a taxpayer or the Internal Revenue Service Independent Office of Appeals may request non-binding mediation on any issue unresolved at the conclusion of—
**(A)** appeals procedures; or
**(B)** unsuccessful attempts to enter into a closing agreement under section 7121 or a compromise under section 7122.
**(2)** **Arbitration** The Secretary shall establish a pilot program under which a taxpayer and the Internal Revenue Service Independent Office of Appeals may jointly request binding arbitration on any issue unresolved at the conclusion of—
**(A)** appeals procedures; or
**(B)** unsuccessful attempts to enter into a closing agreement under section 7121 or a compromise under section 7122.
**(c)** **Administrative appeal relating to adverse determination of tax-exempt status of certain organizations**
**(1)** **In general** 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).
**(2)** **Adverse determinations** For purposes of paragraph (1), an adverse determination is described in this paragraph if such determination is adverse to an organization with respect to—
**(A)** 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),
**(B)** the initial classification or continuing classification of the organization as a private foundation under section 509(a), or
**(C)** the initial classification or continuing classification of the organization as a private operating foundation under section 4942(j)(3).
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**Source Credit**: (Added Pub. L. 105–206, title III, § 3465(a)(1), July 22, 1998, 112 Stat. 768; amended Pub. L. 114–113, div. Q, title IV, § 404(a), Dec. 18, 2015, 129 Stat. 3118; Pub. L. 116–25, title I, § 1001(b)(1)(G), July 1, 2019, 133 Stat. 985.)
## Editorial Notes
### Prior Provisions
A prior section 7123 was renumbered .
### Amendments
2019— substituted “Internal Revenue Service Independent Office of Appeals” for “Internal Revenue Service Office of Appeals” wherever appearing.
2015—Subsec. (c). added subsec. (c).
## Statutory Notes and Related Subsidiaries
### Effective Date of 2015 Amendment
> “The amendment made by subsection (a) [amending this section] shall apply to determinations made on or after
>
> .”
, , , provided that: