Note:

The signature of the parties on the FTS Report does not constitute a final settlement, nor does it waive restrictions on assessment, terminate consents to extend periods of limitation, start the running of any periods of limitation, or constitute agreement to close the case.

If the taxpayer accepts the FTS AO’s settlement proposal, but the Group Manager rejects it, the Area Manager must review the settlement proposal and either concur in writing with the rejection or accept the settlement proposal on behalf of EP/EO. If the Area Manager:

Accepts the settlement proposal, the case is processed under established procedures for an agreed case.

Concurs with the Group Manager’s rejection of the settlement proposal, and an acceptable alternative settlement is not reached, the issue is closed out of the FTS program as unagreed.

If the parties cannot reach an agreement, process the case under normal “unagreed” procedures.