The U.S. IRS and Department of the Treasury have issued final regulations on the Resolution of Federal Tax Controversies by the Independent Office of Appeals, which were published in the Federal Register on 15 January 2025. The regulations generally apply to relevant requests for consideration by the IRS Independent Office of Appeals made on or after 14 February 2025. --- SUMMARY: 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...