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IRS Seeks to Improve Dispute Resolution Programs

S.J. Steinhardt
Published Date:
Aug 8, 2023

The IRS is asking the public for suggestions on how to improve its existing post-filing alternative dispute resolution (ADR) programs for taxpayers.

Over the past two decades, the IRS has offered four principal post-filing ADR programs, which aim to resolve disputes quickly, efficiently and without litigation. They are: Fast Track Settlement (FTS)Fast Track Mediation—Collection (FTMC); Rapid Appeals Process (RAP); and Post Appeals Mediation (PAM).

The IRS seeks input on the following matters:

● Reasons why taxpayers choose not to use these ADR programs,and potential modifications to these programs that can remedy taxpayer concerns;
● Issues that are currently excluded from these ADR programs that should not be excluded;
● Other ways in which these ADR programs could be improved;
● Suggestions for how best to educate taxpayers and representatives about these ADR programs;
● Experiences with the use of mediators from the IRS Independent Office of Appeals (Appeals), and suggestions for how Appeals can ensure that mediators promote an ADR engagement that is conducive to settlement;
● Suggestions for how best to extend the use of these or other ADR programs to taxpayer segments that may be less aware of, or familiar with, ADR, such as small business and low-income taxpayers, and whether any unique characteristics of these segments necessitate modified ADR procedures;
● Feedback about experiences with the IRS when ADR programs were offered or not offered by IRS personnel or were denied when requested by taxpayers;
● Feedback about whether there are types of cases where ADR has proven particularly useful (e.g., valuation cases) and, if so, how ADR use can be increased in these types of cases; and
● Ideas to achieve tax certainty or resolution sooner beyond these existing ADR programs, including ideas for new ADR programs.

"The IRS is greatly interested in examining ways to help to reduce the time, costs and administrative burden for taxpayers and the government in resolving tax disputes," said Andy Keyso, chief of Appeals. "We're open to all suggestions about how to better use ADR techniques to help expedite their fair resolution."

All comments beyond the items listed above are welcome. Public comments can be sent to by Aug. 25, 2023.

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