If you have an IRS tax debt and are unable to achieve a satisfactory resolution with the office originally assigned to handle your matter, you may need to call on the IRS Appeals Office to take a second look. Last time I wrote about the procedures and steps leading up to Appeals. Today I will discuss some of the options available to taxpayers already in Appeals.
Once the controversy has advanced to the stage of appeals the IRS offers a variety of “alternative dispute resolution” options designed to keep the matter out of court.
The mission of Appeals is to resolve tax controversies, without litigation, on a basis that is fair and impartial to both the Government and the taxpayer, and in a manner that will enhance voluntary compliance and public confidence in the integrity and efficiency of the Service.
Fast Track Mediation (FTM)
- Intended for Small Business/Self Employed taxpayers
- Case remains in SB/SE
- Parties must agree to FTM using Form 13369
- Taxpayer meets with IRS representative and third party Appeals personnel
- Solution normally reached within 40 days
- Solution is not binding (i.e., parties are not obligated to accept the outcome)
- Automated Collection Service (ACS) cases excluded
Fast Track Settlement (FTS)
- Available to most other taxpayers (not just SB/SE)
- Must complete application, Form 14017
- Decision normally reached with 60-120 days
- Taxpayer may withdraw at any time and retains all traditional appeal rights
- For factual issues only (no legal issues)
- Outcome is binding
- Most collection issues excluded