EO - Fast Track Settlement Conclusion

If the taxpayer accepts the FTS AO’s settlement proposal, but the EO GM rejects it, the EO area manager must review the settlement proposal and either concur in writing with the rejection or accept the settlement proposal on behalf of EO.

If the area manager accepts the settlement proposal, process the case in accordance with the proposal.

If the area manager concurs with the GM’s rejection of the settlement proposal, and an acceptable alternative settlement cannot be reached, the issue closes out of the FTS program as unagreed.

Include any resolution of an issue (or disagreement) through the FTS process for specified tax periods in your workpapers. Appropriately index the resolution in the Form 5773 to support your conclusions.

A resolution by the parties through the FTS process won’t bind the parties for taxable periods or issues not covered by the FTS agreement, unless addressed expressly in a closing agreement reached as part of the FTS process.

If the parties can’t reach an agreement, process the case under normal "unagreed" procedures.