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Internal Revenue Manual Part 4. Examining Process · 2026-10-03 edition · updated 2026-10-04 · United States
To participate in FTS, the taxpayer must consent, pursuant to IRC 6103(c), to the disclosure of the taxpayer's returns and return information pertaining to the issues being considered in the FTS process to those persons named on Form 14017.
Write up all unagreed issues in a RAR format. Use Form 5701 for this purpose. Add Form 886-A if more room is needed.
The taxpayer must prepare a full written response explaining their position on each issue.
Assemble the FTS Submission Package:
Form 14017.
Form 5701 and RAR.
The taxpayer’s written response.
Your rebuttal.
Submit the FTS Submission Package to your GM for signature on Form 14017.
Secure email the FTS Submission Package to the area manager.
The area manager approves the FTS Submission Package by signing Form 14017 as the approving operating division official.
Secure email the FTS Submission Package approved by your area manager to the Appeals Program Manager using the mailbox ap.tege.fts@irs.gov.
The Appeals Program Manager (or designee) contacts the EO GM to inform them of the decision made regarding acceptance or rejection in FTS.
If accepted, the Appeals Program Manager (or designee) assigns an FTS Appeals Officer who acts as the FTS Appeals Official (FTS AO) to help resolve the case.
If the case isn't accepted for inclusion in FTS:
Notify the taxpayer accordingly.
Discuss other dispute resolution opportunities with the taxpayer, including closing agreement or 30-day letter procedures and the taxpayer's normal Appeal rights.
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