SECTION 2. OVERVIEW

.01 In furtherance of the Service’s goal of resolving tax controversies on a basis that is fair and impartial to both the government and the taxpayer, the Service implemented an LMSB Fast Track Dispute Resolution Pilot Program in Notice 2001–67, 2001–2 C.B. 544. The pilot program demonstrated that the Service can successfully use dispute resolution techniques within LMSB to promote issue resolution at earlier stages and decrease the overall time from return filing to ultimate issue resolution. The FTS program, which the Service has structured to promote resolution within 120 days of acceptance into the program, builds on the success of the pilot program.

2003–25 I.R.B. 1044 June 23, 2003

with the LMSB Fast Track Agreement to complete the package. Taxpayers do not need to submit a formal protest for FTS. The LMSB Team Manager will coordinate preparation and submission of the application package.

.02 All applications to the FTS program require the approval of the Fast Track Program Managers before acceptance into FTS. If the Fast Track Program Managers approve the application, the FTS Appeals Official ( see section 5.01 below), will notify the taxpayer and the LMSB Team Manager. If the Fast Track Program Managers do not approve the application, the Appeals Fast Track Program Manager will notify the LMSB Team Manager within ten days of receipt of the application. The LMSB Team Manager will, in turn, notify the taxpayer. The decision not to approve an application for the FTS program is final and not subject to administrative appeal or judicial review.

.03 The parties and the FTS Appeals Official will agree to and document a projected completion date on the LMSB Fast Track Agreement form. The goal of the FTS program is to complete the entire FTS process in approximately 120 days. The LMSB Team Manager and the taxpayer will also identify a preferred conference site.