(2) DISCRETION.—The exercise of authority 
under paragraph (1) shall be at the sole discretion 
of the Commissioner of Internal Revenue and may 
not be delegated to any other officer. At the sole dis-
cretion of the Commissioner of Internal Revenue, 
such Commissioner may establish a procedure which 
will be used to determine whether an individual 
should be referred to the Commissioner of Internal 
Revenue for a determination by the Commissioner 
under paragraph (1). 
(3) NO
APPEAL.—Any determination of the 
Commissioner of Internal Revenue under this sub-
section may not be appealed in any administrative or 
judicial proceeding. 
(d) TIGTA REPORTING OF TERMINATION OR MITI-
GATION.—Section 7803(d)(1)(E) of the Internal Revenue 
Code of 1986 is amended by inserting ‘‘or section 6 of 
the Small Business Taxpayer Bill of Rights Act of 2022’’ 
after ‘‘1998’’. 
SEC. 7. RIGHT TO INDEPENDENT CONFERENCE. 
Section 1001 of the Internal Revenue Service Re-
structuring and Reform Act of 1998 is amended by redes-
ignating subsection (c) as subsection (d) and by inserting 
after subsection (b) the following new subsection: 
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‘‘(c) RIGHT
TO
INDEPENDENT
CONFERENCE.— 
Under the organization plan of the Internal Revenue Serv-
ice, a taxpayer shall have the right to a conference with 
the Internal Revenue Service Independent Office of Ap-
peals which does not include personnel from the Office of 
Chief Counsel for the Internal Revenue Service or the 
compliance functions of the Internal Revenue Service un-
less the taxpayer specifically consents to the participation 
of such personnel.’’. 
SEC. 
8. 
ALTERNATIVE 
DISPUTE 
RESOLUTION 
PROCE-
DURES. 
(a) IN GENERAL.—Section 7123 of the Internal Rev-
enue Code of 1986 is amended by adding at the end the 
following new subsection: 
‘‘(d) AVAILABILITY OF DISPUTE RESOLUTIONS.— 
‘‘(1) IN GENERAL.—The procedures prescribed 
under subsection (b)(1) and the pilot program estab-
lished under subsection (b)(2) shall provide that a 
taxpayer may request mediation or arbitration in 
any case unless the Secretary has specifically ex-
cluded the type of issue involved in such case or the 
class of cases to which such case belongs as not ap-
propriate for resolution under such subsection. The 
Secretary shall make any determination that ex-
cludes a type of issue or a class of cases public with-
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in 5 working days and provide an explanation for 
each determination. 
‘‘(2) INDEPENDENT MEDIATORS.— 
‘‘(A) IN GENERAL.—The procedures pre-
scribed under subsection (b)(1) shall provide 
the taxpayer an opportunity to elect to have the 
mediation conducted by an independent, neutral 
individual not employed by the Internal Rev-
enue Service Independent Office of Appeals. 
‘‘(B) COST AND SELECTION.— 
‘‘(i) 
IN
GENERAL.—Any 
taxpayer 
making an election under subparagraph 
(A) shall be required— 
‘‘(I) to share the costs of such 
independent mediator equally with the 
Internal Revenue Service Independent 
Office of Appeals, and 
‘‘(II) to limit the selection of the 
mediator to a roster of recognized na-
tional or local neutral mediators. 
‘‘(ii) EXCEPTION.—Clause (i)(I) shall 
not apply to any taxpayer who is an indi-
vidual or who was a small business in the 
preceding calendar year if such taxpayer 
had an adjusted gross income that did not 
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