IRS to test faster dispute resolution

Easing restrictions, sharpening personal attention and clarifying denials are among the aims of three pilot programs at the Internal Revenue Service that will test changes to existing alternative dispute resolution programs. 

The programs focus on “fast track settlement,” which allows IRS Appeals to mediate disputes between a taxpayer and the IRS while the case is still within the jurisdiction of the examination function, and post-appeals mediation, in which a mediator is introduced to help foster a settlement between Appeals and the taxpayer.

The IRS has been revitalizing existing ADR programs as part of transformation efforts of the agency’s new strategic plan, said Elizabeth Askey, chief of the IRS Independent Office of Appeals.

“By increasing awareness, changing and revitalizing existing programs and piloting new approaches, we hope to make our ADR programs, such as fast-track settlement and post-appeals mediation, more attractive and accessible for all eligible parties,” said Michael Baillif, director of Appeals’ ADR Program Management Office. 

Among other improvements, the pilots: 

• Align the Large Business and International, Small Business and Self-Employed and Tax Exempt and Government Entities divisions in offering FTS issue by issue. Previously, if a taxpayer had one issue ineligible for FTS, the entire case was ineligible. 
• Provide that requests to participate in FTS and PAM will not be denied without the approval of a first-line executive. 
• Clarify that taxpayers receive an explanation when requests for FTS or PAM are denied.

Another pilot, Last Chance FTS, is a limited scope SB/SE pilot in which Appeals will call taxpayers or their representatives after a protest is filed in response to a 30-day or equivalent letter to inform taxpayers about the potential application of FTS. This pilot will not impact eligibility for FTS but will simply test the awareness of taxpayers regarding the availability of FTS. 

A final pilot removes the limitation that participation in FTS would preclude eligibility for PAM. 

The traditional appeals process remains available for all taxpayers. 

Inquiries can be addressed to the ADR Program Management Office at ap.adr.programs@irs.gov.