SECTION 6. FAST TRACK DISPUTE

RESOLUTION PROCEDURE CONTINGENT LIABILITY CASES

.01 A Taxpayer electing the Fast Track Dispute Resolution Procedure - Contingent Liability Cases must participate in binding arbitration to resolve any issues that are not resolved in the accelerated settlement negotiations. See Section 7 below. A Taxpayer that elects the Fast Track Dispute Resolution Procedure - Contingent Liability Cases will not be eligible for any other settlement, mediation or arbitration procedure.

.04 The Taxpayer will be notified in writing within 15 calendar days of the receipt of a complete application as to whether the Taxpayer’s election has been accepted as in compliance with the eligibility and application requirements of this revenue procedure for the resolution methodology selected in the application. A Taxpayer becomes an electing taxpayer (“Electing Taxpayer”) for purposes of this revenue procedure, after it has been notified that its application has been accepted.

.05 If the Service denies a Taxpayer’s application for participation under the Fixed Concession Procedure because the Taxpayer does not satisfy either criterion under Section 5.01, the application may be amended in writing within 10 days of receipt of the notice issued under Section 4.04 to elect the Fast Track Dispute Resolution Procedure - Contingent Liability Cases set forth in Section 6.

.06 Denial of a Taxpayer’s request to participate in either resolution methodology is not subject to judicial review.