Talking to Law360 Tax Authority, partner Michael Kummer discussed a proposed rule that would establish how the Internal Revenue Service (IRS) will operate its Independent Office of Appeals to resolve federal tax controversies that do not require litigation. Michael said there many details in the notice of proposed rulemaking that will be of interest to taxpayers, especially the definition of what constitutes a federal tax controversy and the exceptions to review by the Independent Office of Appeals: “Taxpayers and others will want to review the proposed regulations to figure out what's included and what's excluded from the definition when thinking about their rights of access to appeals.”