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December 8, 2016


Mediate with the IRS? Updates to fast-track settlement options

Sometimes tax litigation can’t be avoided. When the IRS is being unreasonable, you need to protect your interests.

In other situations, however, it may make sense for both sides to come to an agreement.

The IRS seems to realize this too and recently made changes to its mediation procedures.
More specifically, it has added a new procedure called Fast Track Mediation-Collection (FTMC).

The IRS began working on creating a fast-track mediation procedure in 2000. Fast Track Mediation (FTM) enabled taxpayers with cases being handled by the Examination or Collection units to speed up resolution by using a mediator from the IRS Appeals unit as a third party.

The FTMC program recently announced by the IRS replaces the earlier FTM program. The reason for the change is to encourage greater use of the program.

The previous program was not used very often. This was especially true after the IRS rolled out a similar program in 2013 that applied to the Examination Unit. That program was called the Fast Track Settlement (FTS) program.

The FTMC program is aimed at cases being handled by the IRS Collection unit. This includes offer-in-compromise cases, as well as those involving the trust fund recovery penalty.

A mediator from the IRS Office of Appeals still works for the IRS. But the mediator may still be in a position to facilitate a sensible resolution of the disputed issue or issues. This is something you’ll want to discuss with your tax attorney, to find out whether you are eligible and make sure you are clear on what is best for your specific situation.

Tax Controversy