EO - Initial Process for Cases Accepted in FTS
Internal Revenue Manual Part 4. Examining Process · 2026-10-03 edition · updated 2026-10-04 · United States
If the case is accepted in FTS, the FTS AO:
Contacts the EO GM (or EO examiner) and the taxpayer to set up an FTS session to discuss case resolution.
Holds the FTS session at the date and location agreed to by both parties.
Meets with the taxpayer, the EO GM (or designee) and the examiner at the FTS session.
Serves as a neutral party at the FTS session.
Doesn’t perform in a traditional Appeals role, but uses dispute resolution techniques to facilitate settlement between the parties.
The taxpayer doesn’t need to have a representative to participate in the FTS process, but if they do, this individual must have a power of attorney from the taxpayer (Form 2848, Power of Attorney and Declaration of Representative).
The FTS AO may ask you and the taxpayer to limit the number of participants at the FTS session to facilitate the process.
Before the FTS session, the FTS AO advises the participants of the procedures and establish ground rules.
Generally, the FTS AO considers only those issues outlined in the FTS Report, except by mutual agreement of the parties.
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