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Overview
Fast Track Settlement (FTS) is a voluntary mediation program that provides a way to resolve tax disputes during the examination process. You can request an FTS for most examination disputes once the examiner has completed their work and there are issues that remain unresolved. The goal of FTS is to resolve the case in 60 days (or 120 days for large businesses or businesses with international interests).
With FTS, an independent mediator from the IRS Independent Office of Appeals serves as a neutral party to facilitate an agreement between you and the IRS on the disputed issue(s).
Choosing FTS may result in:
If you do not agree with issues the IRS raises during the examination process, discuss the option of an FTS with the examiner. Keep in mind, you must have a conference with the group manager first before filing an FTS. You as the taxpayer, the examiner, or the Exam group manager may initiate the FTS process at any time after the IRS fully develops an audit issue but preferably before the IRS issues a 30-day letter or equivalent. You may not initiate an FTS after the IRS sends you the 90-day letter (Letter 3219 or equivalent).
You should agree with the examiner and the group manager on all the facts and circumstances. You and the examiner must have raised all issues and claims and you must have presented all documentation prior to the submission of the FTS application to the IRS Independent Office of Appeals.
If you decide an FTS is right for you and the IRS approves your FTS application, there are ways you can prepare for a successful mediation.
Because FTS is voluntary, the mediator can’t force you or the IRS to participate or to accept a proposed agreement. You retain control over decisions you make about your case.
If you are unable to resolve your dispute through FTS, you will still have the right to request a traditional appeal or a conference with an IRS manager.
Fast Track Settlement: A Process for Prompt Resolution of Small Business and Self Employed Tax Issues
Fast Track Settlement: A Process for Prompt Resolution of Large Business and International Tax Issues
Fast Track Settlement: A Process for Prompt Resolution of Tax Exempt and Government Entities (TE/GE) Tax Issues
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The Taxpayer Advocate Service is an independent organization within the IRS. TAS helps taxpayers resolve problems with the IRS, makes administrative and legislative recommendations to prevent or correct the problems, and protects taxpayer rights. TAS helps all taxpayers (and their representatives), including individuals, businesses, and exempt organizations. You may be eligible for free TAS help if your IRS problem is causing financial difficulty, if you’ve tried and been unable to resolve your issue with the IRS, or if you believe an IRS system, process, or procedure just isn’t working as it should.
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