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APPEALS MEDIATION PROGRAMS - Online Self-Help Tool (8)

The Large Business and International Appeals FAST TRACK SETTLEMENT (FTS) program is designed to resolve disputes between you and your IRS auditor while your case is still under examination. Once your FTS application is accepted, the goal is resolution within 120 days.


Your IRS auditor is your best source for information about the FTS program.


Certain cases and issues are not eligible for FTS:

  • Issues designated for litigation or under consideration for designation for litigation
  • The facts and circumstances involving the disputed issue are not sufficiently developed by the taxpayer and/or the LB&I examiner, making mediation premature
  • Issues for which you have requested the simultaneous Appeals/Competent Authority procedure described in section 8 of Rev. Proc. 2002-52, or the corresponding provision of any successor guidance
  • "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
  • Other issues listed in section 3 of Rev. Proc. 2003-40
 

If one issue is found not eligible for the FTS program, all issues in the case will be ineligible for the FTS program.


My case or disputed issue is not among those listed above or in Rev. Proc. 2003-40 and I want to learn about the FTS application process:

 

Page Last Reviewed or Updated: 10-Jan-2014