IRS
announces nationwide rollout of Fast Track Settlement program for small
businesses and self-employed individuals
On
November 6, 2013, the IRS announced the nationwide roll out of its Fast Track
Settlement (“FTS”) program, a streamlined program designed to help small
businesses and self-employed individuals who are under examination by the IRS’
Small Business/Self Employed (“SB/SE”) Division more quickly settle their
differences with the IRS. Prior to yesterday’s announcement, the FTS program
was a pilot program whose availability was limited to certain jurisdictions.
The
FTS program, now available nationwide, is structured to expedite SB/SE case
settlement through alternative dispute resolution techniques. The techniques
utilized by the program, as stated in the IRS’ Announcement 2011-5, “enable
SB/SE taxpayers that currently have unagreed issues in at least one open year
under examination to work together with SB/SE and the Office of Appeals to
resolve outstanding issues while the case is still in SB/SE jurisdiction.” The
program is designed to save taxpayers time and to avoid formal appeals and
lengthy litigation processes.
Subject
to certain exceptions listed in Announcement 2011-5, the FTS program is
generally available for cases under the jurisdiction of the IRS’ SB/SE Division
if: (1) the issue(s) in dispute are fully developed, (2) the taxpayer has
submitted a written statement responding to the IRS’ position on the disputed
issue(s) and (3) there are a limited number of issues in dispute. A taxpayer
who is interested in participating in the FTS program, or who has questions
about the program and its suitability for the taxpayer’s case, should contact
the Examination or Specialty Program group manager for the audit. To apply for
the FTS program, the taxpayer and the group manager must submit a Form 14017,
Application for Fast Track Settlement to the Appeals Team Manager, along with
the taxpayer’s written response to the IRS’ stated position on the disputed
issue(s). More background on the program and the application process is
provided in Announcement 2011-15 and on the IRS’ Alternative Dispute Resolution
webpage.
