The IRS Appeals Office plays an important role in seeking the resolution of federal tax issues before taxpayers have to pursue expensive court remedies. Indeed, the Appeals Office’s primary purpose is to promote compromise and settlement. An historical problem has been that once a case gets to the Appeals Office, it often languishes for months.  One strategy to avoid delay would focus on Appeals’ Alternative Dispute Resolution (ADR) Program.  The (ADR) Program includes “fast track” settlement and mediation procedures closely monitored so that they can ideally be completed within two to four months after referral. When cases qualify, and a number of types of cases do not, taxpayers and the IRS may begin either the settlement or the mediation process after an audit is largely completed and the issues developed, but before a 30-day letter is issued. This hastens the resolution process and avoids the long delays inherent in preparing a protest and awaiting assignment to an Appeals officer and an eventual conference date. During fast track settlement, the taxpayer, an examination division manager and an appeals officer work closely together to craft a settlement. For fast track mediation, the Appeals Office assigns a representative with mediation expertise. As a practical matter, efforts to settle may start with mediation to bring the parties together and then continue toward eventual settlement. Appeals officers are authorized during the fast track settlement process to offer a settlement. A taxpayer’s agreement, or request, to seek fast track resolution does not bind him to one process or the other. The taxpayer may decide at any time to opt out of the mediation or settlement effort and thereafter pursue his normal Appeals remedies.

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