(1) Mediation The Secretary shall prescribe procedures under which a taxpayer or the Internal Revenue Service 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 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.
