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Fast Track Settlement Procedures

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.

Announcement 2008-105, IRB 2008-48, 1219 established FTS for certain unagreed issues that are ineligible for resolution under EPCRS or a DO 8-3 agreement for EP and for certain EO, FSL/ET cases, so that they could be resolved while the case is still open in the group. The program was made permanent under Announcement 2012-34, 2012-36 IRB 334. This Announcement contains procedures as well as the types of issues that are eligible for FTS.

The goal of FTS is to resolve the issue within 60 calendar days from the date an EP or EO case is accepted in the FTS program, and 120 days for FSL/ET cases.

Find additional information regarding this program in Pub 5092, Fast Track Settlement A Process Resolution of Tax Exempt and Government Entities (TE/GE) Tax Issues, and at the Appeals Alternative Dispute Resolution Program FTS website Pages - Fast Track Settlement (FTS) (irsnet.gov).

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▸Contents — Internal Revenue Manual Part 4. Examining Process
Internal Revenue Manual Part 4. Examining Process

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