Fast Track Settlement An Option for a Better Resolution?

Along with the advent of the new Large Business & International (“LB&I”) division of the Internal Revenue Service (“IRS”) (see earlier post regarding the new division), comes the joint dispute resolution division known as the LB&I/Appeals Fast Track Settlement program (“FTS”). TheFTS program (which is also available for other divisions) has been touted by the IRS as a method for qualifying taxpayers to have their disputes resolved with an IRS Appeals Officer in 120 days or less a process that can easily surpass 2 years under normal resolution procedures. Appeals officers have mediation and delegated settlement authority. Qualifying for this program requires the completion of a one-page form (Form 14017) and is generally available to taxpayers who are already within theLB&I division and can also be used to resolve certain disputed issues before the tax return is filed. In addition to the reduction in the length of the time for resolution, theFTS program has additional goals of providing independent reviews and ensuring that all parties participate in the mediation and resolution. Participation is voluntary and the taxpayer may withdraw from the process after it has begun. On September 23, 2010, the IRS announced that theFTS program has proven to be successful with an 85% resolution rate. –Elaina L. Blanks