EO - Fast Track Settlement (FTS)
Internal Revenue Manual Part 4. Examining Process · 2026-10-03 edition · updated 2026-10-04 · United States
TE/GE and Appeals jointly administers FTS, an alternative dispute resolution program designed to help taxpayers settle disputes at the examination group level. An appeals officer trained in mediation serves as an impartial third party to resolve unagreed TE/GE issues by:
Facilitating settlement negotiations.
Using mediation techniques and sometimes settlement authority.
The goal of TE/GE FTS is to resolve the issue within 60 calendar days. The benefits of TE/GE FTS include less time, expense, and burden on both the taxpayer and the government.
You or the taxpayer may consider the FTS process at any time after you fully develop a disputed issue but before you issue a formal examination report (30-day letter and RAR). FTS may be allowed in specific situations when the taxpayer provides new information after the 30-day letter is mailed. In all situations, FTS must be initiated before the mailing of the 90-day letter.
Get a plain-English answer with a citation back to this text.
Ask AI about this code