This Comment examines the development of the new tax mediation program, its procedures and application, and its current status. Part II reviews the Appeals process leading up to and including the choice of an avenue to resolution of taxpayer disputes other than litigation. Part III explores the new mediation program including the scope of the cases allowed, the requirements for initiating the process and the procedures for implementing the program. Part IV discusses the policy reasons behind the IRS' implementation of the specific procedures and criteria into the new tax mediation program. Finally, Part V is an update of the success and current status of the mediation program.



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