The Chief Counsel should coordinate with the BOD Commissioners on cases other than those the IRS has designated for litigation to develop and implement: 1) guidance that clearly defines matters for which Appeals consideration has been denied and is required to follow I.R.C. § 7803(e)(5), 2) a process for obtaining approval to deny a taxpayer’s appeal under I.R.C. § 7803(e)(5) as well as a mechanism to track these types of cases, and 3) procedures to respond to a taxpayer’s protest of a denied appeal under I.R.C. § 7803(e)(5).