The joint Large Business and International (LB&I) Division/Appeals Fast Track Settlement program (FTS) offers a customer-driven approach to resolving tax disputes at the earliest possible stage in the examination process. This program is designed to:
- Provide an independent Appeals review of the dispute in an environment where all parties to the dispute have a “voice” in the dispute resolution process,
- Utilize the mediation skills and delegated settlement authority of Appeals, and
- Reduce the length of a taxpayer’s overall IRS experience.
Applying for IRS Fast Track Settlement
Applying for Fast Track Settlement is quick and easy – simply complete a one-page application. A formal written protest is not required. Once the case is accepted into the FTS program, an Appeals official will serve as a facilitator to arrive at and execute a resolution or settlement that is mutually agreeable to all parties.
What is IRS Fast Track Settlement?
Fast Track Settlement is designed to help other IRS Operating Division taxpayers expeditiously resolve disputes during an examination while their case is still in Examination or Collection. Fast Track Settlement brings Appeals resources to a mutually agreed upon location to resolve the dispute before the 30-day letter is issued. A specially trained Appeals employee facilitates the discussion between you and the revenue agent and their team or group manager to reach and execute a settlement with which you both agree.
Requesting IRS Fast Track Settlement
You may request Fast Track Settlement after Form 5701, Summary of Issues, Examination Re-Engineering Lead Sheets or other similar document has been issued and you have provided a written response. FTS may be available for factual and legal issues, including listed transactions, Compliance and Appeals Coordinated Issues, and issues that require consideration of the hazards of litigation.
IRS Fast Track Settlement Benefits
Your benefits with Fast Track Settlement include: • A one-page application, Form 14017 ; • Consideration of the hazards of litigation; • An answer within 120 days for Large Business and International (LB&I) cases and within 60 days for Small Business Self Employed (SB/SE) and Tax Exempt Government Entities (TE/GE) cases; • No ‘hot’ interest under IRC 6621; • An option to withdraw from the process at any time; • Retention of all traditional appeal rights; • Significantly shorter IRS experience; • Only one tax computation; • Your case closes agreed in the other Operation Division; and • Immediate use of Delegation Order 236