California Tax Attorney Mitchell Port writes about the IRS’s post-appeals mediation and arbitration programs (Fast Track Settlement Pilot Program) for Offers in Compromise and the assessments of Trust Fund Recovery Penalties:
Under these two alternative dispute resolution programs, the taxpayer or Appeals may request nonbinding mediation. The taxpayer may decline Appeals’ request for mediation. Appeals will evaluate a taxpayer’s request for mediation based on the criteria detailed in Revenue Procedure 2002-44 and Announcement 2008-111. A request for binding arbitration must be made jointly by the taxpayer and Appeals. The mediation and arbitration procedures do not create any additional authority for settlement by Appeals.
The IRS has published the procedures for participation in the test period of the mediation and arbitration programs, which has been extended to December 10, 2010.
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IRS Announces New Mediation Program for Offers in Compromise and Trust Fund Recovery Penalties
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