EO - Characteristics of Fast Track Settlement

FTS resolves factual and legal issues.

FTS enables the taxpayer to work with the EO examiner, the EO GM and Appeals.

All three parties (examination group, taxpayer, and Appeals) are active participants in the process.

All three must agree before a proposed resolution can be put in place.

Both parties must commit to settling the issues involved.

The prohibition against ex parte communications (Public Law 105-206, Section 1001(a)) between Appeals Officers and other IRS employees doesn't apply to the FTS process. See Rev. Proc. 2012-18, Section 2.05. Appeals personnel:

Ease agreement between the taxpayer and EO.

Don’t act in their traditional Appeals settlement role.

If the parties fail to resolve any issue in FTS, the taxpayer retains the right to protest the issue through the traditional Appeals process.