Alternative Dispute Resolution |
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Fast Track Settlement (Large & Mid-Size Division Taxpayers)
Fast Track Settlement (FTS) offers Large and Mid-Size Business Division (LMSB) taxpayers a way to resolve audit issues during the examination process in less than 120-days. Working with LMSB and Appeals, taxpayers can use the settlement authority and mediation skills of Appeals to shorten their overall experience with the Internal Revenue Service. FTS reduces the combined LMSB-Appeals process time by two years. Refer to the following for more information.
Fast Track Settlement (Small Business and Self-Employed Taxpayers)
Small Business/Self-Employed (SB/SE) and Appeals designed a alternative dispute resolution strategy for small business and self employed (SB/SE) taxpayers, called SB/SE Appeals Fast Track Settlement (FTS). This program offers a way to resolve audit issues during the examination process in less than 60-days, by using the settlement authority and mediation skills of Appeals. A two-year test of the program began on September 6, 2006, in Chicago, St. Paul and Houston, and then was expanded to include taxpayers in Philadelphia, San Diego, Laguna and Riverside. Appeals and SB/SE have extended the test for another year to gather additional information, evaluate the program, consider necessary adjustments, and determine whether to make the program permanent. If you are from these testing cities and you wish to take part, then use the Form 14017 "Application for Fast Track Settlement" available below.
Refer to the following for more information:
Fast Track Mediation (Small Businesses and Self-Employed Taxpayers)
Fast Track Mediation (FTM) gives Small Businesses, Self-Employed (SE/SE) taxpayers and the IRS the opportunity to mediate disputes through an IRS appeals officer, who acts as a neutral party. In this program, most tax disputes are resolved within 40 days compared to several months though the regular appeal process. IRS offers this new service designed to expedite case resolutionon disputes that arise from examination or collection actions.
Arbitration
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- IRB 2000-3 Pursuant to section 7123(b)(2) of the Code, Appeals is conducting a 2-year test of a binding arbitration procedure (Arbitration - Announcement 2000-4, 2000-3 IRB 317)
This announcement contains procedures that taxpayers may use to request binding arbitration for factual issues that are already in the Appeals administrative process and which are not docketed in any court.
Early Referral
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Early Referral Request ( Rev. Proc 99-28, 1999-29 IRB 109)
The IRS has issued guidance describing the method by which a taxpayer may request an early referral of one or more unresolved issues from the Examination or Collection Division to the Office of Appeals.
Post Appeals Mediation
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Appeals mediation procedure ( Mediation - Rev. Proc.2002-44, 2002-26 IRB 10)
This document formally establishes the Appeals mediation procedure and modifies and expands the availability of mediation for cases that are already in the Appeals administrative process.
Simultaneous Appeals/Competent Authority
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Simultaneous Appeals/Competent Authority Revenue Procedure 2002-52 ( IRB 2002-31 (8/5/02) page 242)
The simultaneous Appeals/competent authority procedure encourages taxpayers to request competent authority assistance and the participation of Appeals while a case is under the Examination Division's jurisdiction. Revenue Procedure 2002-52 contains the competent jurisdiction. Revenue Procedure 2002-52 contains the competent authority procedures. Section 8 of Rev. Proc 2002-52 specifies the circumstances under which the simultaneous appeals/competent authority procedure may be requested and describes the role of Appeals.
References
- Tax Exempt Bonds (Rev Proc 03-36)
The IRS has provided procedures for bond issuers to request an administrative appeal of a proposed adverse determination by a Employee Plans/Exempt Organizations Key District that the interest on their bonds is not excludable from gross income under Code Sec. 103.
- Settlement Offers and Closing Agreements in Coordinated Examination Program Cases Where Appeals has Effected a Settlement (Delegation Order 236 (Rev.3))
- Authority of Examination Case Managers to Accept Settlement Offers and Execute Agreements on Industry Specialization (ISP) and International Field Assistance Specialization Program (IFASP) Issues is a new examination tool which can be used to settle appropriate issues at the case manager level. (Delegation Order 4-25)
- Valuing Artwork (Rev. Proc.96-15, 1996-3 IRB 41)
Valuing artwork is important for such tax purposes as estate and gift taxes and the charitable contribution deduction. Rev. Proc. 96-15, 1996-3 IRB 41, tells taxpayers how to obtain an IRS review of their art-work valuations before filing returns.
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Page Last Reviewed or Updated: January 08, 2009