IRS testing changes to alternative dispute resolution programs

January 22, 2025

The IRS recently announced three pilot programs that will test changes to existing alternative dispute resolution (ADR) programs, including fast-track settlements (FTS).

The first pilot program will focus on FTS, under which the Independent Office of Appeals can mediate disputes between a taxpayer and the IRS while the case is within the jurisdiction of the examination function, and post-appeals mediation (PAM), in which a mediator helps settle a case between Appeals and the taxpayer.

Under this pilot program, FTS can apply to one or more issues in a case. Previously, a taxpayer's entire case was ineligible for FTS if the taxpayer had one issue that was ineligible. Additionally, participation in FTS will not disqualify a taxpayer from PAM. See more changes.

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