Post-Appeals Mediation is designed to resolve disputes between you and your Appeals Officer or Settlement Officer while your case is still with the Office of Appeals. Once your PAM application is accepted, the goal is resolution within 60-90 days.
For your case to be considered for PAM, you must first try to resolve all issues with Appeals. This means working cooperatively with your Appeals Officer or Settlement Officer before seeking the services of an Appeals mediator.
PAM is available for both legal and factual disputes. Certain cases and issues are not eligible for PAM:
- Settlement negotiations with the Appeals Officer are not yet complete
- The taxpayer or representative did not negotiate in good faith during settlement negotiations with the Appeals Officer, for example, failed to respond timely to information requests or offers to settle, or failed to address arguments and precedents raised by Appeals
- 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 offer in compromise and Trust Fund Recovery Penalty cases as provided for in Revenue Procedure 2014-63
- Other issues listed in Revenue Procedure 2014-63
My case involves a Trust Fund Recovery Penalty matter.
My case does not involve a Trust Fund Recovery Penalty AND the disputed issue is not among those listed above or in Revenue Procedure 2014-63. I want to learn about the PAM application process:
Mediation is not an available option. End of self-help tool.