Note:

If the parties fail to resolve any issue in FTS, the taxpayer retains the option of requesting that the issue be heard through the traditional Appeals process.

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

If applicable, the IRS will report a proposed resolution reached as a result of FTS to the Joint Committee on Taxation in accordance with IRC 6405.

The IRS may reconsider a proposed settlement, as reflected in a signed FTS Session Report, upon receipt of comments on the proposed settlement from the Joint Committee on Taxation.

If the taxpayer declines to agree with any changes by the IRS upon reconsideration, EP/EO will close the case unagreed, and the taxpayer will retain all the usual rights to request Appeals consideration of any unagreed issues.