Office of Appeals (a) In general Section 7803 is amended by adding at the end the following new subsection: (e) Independent Office of Appeals (1) Establishment There is established in the Internal Revenue Service an office to be known as the Internal Revenue Service Independent Office of Appeals . (2) Chief of Appeals (A) In general The Internal Revenue Service Independent Office of Appeals shall be under the supervision and direction of an official to be known as the Chief of Appeals . The Chief of Appeals shall report directly to the Administrator of the Internal Revenue Service and shall be entitled to compensation at the same rate as the highest rate of basic pay established for the Senior Executive Service under section 5382 of title 5, United States Code. (B) Appointment The Chief of Appeals shall be appointed by the Administrator of the Internal Revenue Service without regard to the provisions of title 5, United States Code, relating to appointments in the competitive service or the Senior Executive Service. (C) Qualifications An individual appointed under subparagraph (B) shall have experience and expertise in— (i) administration of, and compliance with, Federal tax laws, (ii) a broad range of compliance cases, and (iii) management of large service organizations. (3) Purposes and duties of Office It shall be the function of the Internal Revenue Service Independent Office of Appeals to resolve Federal tax controversies without litigation on a basis which— (A) is fair and impartial to both the Government and the taxpayer, (B) promotes a consistent application and interpretation of, and voluntary compliance with, the Federal tax laws, and (C) enhances public confidence in the integrity and efficiency of the Internal Revenue Service. (4) Right of appeal The resolution process described in paragraph (3) shall be generally available to all taxpayers. (5) Limitation on designation of cases as not eligible for referral to Independent Office of Appeals (A) In general If any taxpayer which is in receipt of notice