Post-Appeals Mediation


Post-Appeals Mediation (PAM) lets you and your appeals officer or settlement officer resolve disputes while your case is still under Appeals' consideration. Once your PAM application is accepted, the goal is resolution within 60-90 days.

With PAM, a trained mediator from the IRS Independent Office of Appeals is assigned to help you and your appeals officer or settlement officer reach an agreement on the disputed issue(s). PAM doesn’t create any special authority for settlement by Appeals. You retain full control over every decision you make during the PAM process. No one can impose a decision on either you or Appeals.

The Appeals mediator is specifically trained in mediation techniques and is independent of the Appeals employee with whom you have been working. In annual customer satisfaction surveys conducted by a non-government company, taxpayers like you have consistently given the independence and impartiality of the Appeals mediator the highest rating of all survey questions.

Refer to the Appeals mediation programs page to learn more about how mediation works and the role of the Appeals mediator.

The benefits of settlement over litigation include:

  • Speed.
  • Cost.
  • Flexibility.
  • Control.
  • Reduced risk.

For your case to be considered for PAM, you must first work cooperatively and try to resolve all issues with your appeals officer or settlement officer before seeking the services of an Appeals mediator.

When considering PAM, consider what might happen if your case is not settled. Ask yourself:

  • Am I prepared for what could be lengthy and costly litigation?
  • What is my risk that the litigation will be unsuccessful, and what would the consequences be?

PAM is available for both legal and factual disputes. Certain cases and issues are not eligible for PAM:

  • Offer in compromise (OIC) cases considered by an IRS campus site.
  • Issues docketed in any court, designated for litigation, or under consideration for designation for litigation.
  • "Whipsaw" issues, which are issues for which resolution with respect to one party might result in inconsistent treatment without the participation of the other party.
  • Collection cases, except for certain OIC and Trust Fund Recovery Penalty cases as provided for in Revenue Procedure 2014-63.
  • Other issues listed in Revenue Procedure 2014-63.

To apply for PAM, send your appeals officer or settlement officer a written statement containing:

  1. A specific request for Post-Appeals Mediation, and
  2. A written statement detailing your position on the disputed issue(s).

If you decide PAM is right for you AND your PAM application is approved there are ways to prepare for a successful mediation.

For more information on the PAM program, read Revenue Procedure 2014-63.