Fast Track Settlement offers Small Business/Self-Employed taxpayers an opportunity to resolve tax disputes at the earliest possible stage in the examination process. Once your application is accepted, the goal is resolution within 60 days.
With FTS, a trained mediator from the IRS Office of Appeals is assigned to help you and the IRS reach an agreement on the disputed issue(s). You retain full control over every decision you make during the FTS process. In addition to using mediation techniques to facilitate settlement discussions, the Appeals mediator may offer settlement proposals and use Appeals’ settlement authority, if needed, to resolve the dispute. Either you or the IRS may agree to or deny the Appeals mediator’s settlement proposal.
When considering FTS, consider what might happen if your case is not settled. Ask yourself:
- Am I prepared for what could be a lengthy appeal?
- What is my risk that litigation would be unsuccessful, and what would the consequences be?
For your case to be considered for FTS, you must first try to resolve all issues with the IRS. This means working cooperatively with your IRS auditor, followed by a conference with the auditor’s manager, before seeking the services of an Appeals mediator.
FTS does not eliminate or replace existing dispute resolution options, including your opportunity to request a hearing before Appeals or a conference with an IRS manager. If you cannot resolve your dispute through FTS, you still retain all otherwise applicable appeal rights.
Certain cases and issues are not eligible for FTS:
- Collection Appeals Program, Collection Due Process, Offer-In-Compromise and Trust Fund Recovery cases, except as provided in any guidance issued by the Service;
- Correspondence examination cases worked solely in a Campus/Service Center site;
- Cases in which the taxpayer has failed to respond to Service communications and no documentation has been previously submitted for consideration by Compliance;
- Frivolous issues, such as those listed in Notice 2010-33 or successor guidance
- Other issues listed in Announcement 2011-5
As a final note, the Fast Track Settlement program is typically one of the last steps in dealing with an IRS issue, after all other attempts to resolve the matter have been exhausted. If you believe you may qualify for Fast Track Settlement, or would like to find out if you are, please feel free to contact us. A Dallas CPA truly is an asset in dealing with the IRS, and we’re happy to help taxpayers with tax issues.
