The Internal Revenue Service’s Independent Office of Appeals launched a two-year pilot program designed to increase taxpayers’ awareness and use of post-appeals mediation.
Taxpayers can request post-appeals mediation, or PAM, after an unsuccessful appeals proceeding and, if accepted, the parties meet in an accelerated mediation session to make a final attempt to negotiate a mutually acceptable resolution.
“Appeals is committed to offering Alternative Dispute Resolution programs as a cost-effective option for resolving cases, improving the taxpayer’s experience, and making the best use of IRS resources,” John Hinding, acting chief of appeals, said in a statement.
PAM sessions usually last one day and are facilitated by an appeals mediator with no connection to the case — with an option for taxpayers to provide their own co-mediator — who work to promote settlement negotiations.
Under the PAM pilot, all aspects will remain the same except cases will be reassigned to an appeals team unconnected with the underlying case who will represent appeals in the mediation session.
“PAM proceedings typically have a high level of success, but we are always working with taxpayers, practitioners, and stakeholders to see how to adjust our ADR programs in ways that make our offerings more desirable for taxpayers and that promote quality tax administration,” said Michael Baillif, director of the ADR Program Management Office, in a statement. “As a result, the PAM pilot will make a small structural change in the program that we think could have a big impact.”
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