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 imple

mented a SB/SE Fast Track Mediation program on July 1, 2000. The pilot program demonstrated that the Service can successfully use dispute resolution techniques within SB/SE to promote issue resolution at earlier stages and decrease the overall time from return filing to ultimate issue resolution. The FTM program, which the Service has structured to promote issue resolution within an average of 30 to 40 days from the initial joint discussion between the FTM Appeals Official and the parties, builds on the success of the pilot program.

.02 FTM is optional for the taxpayer. FTM does not eliminate or replace existing dispute resolution options, including the taxpayer’s opportunity to request a hearing before Appeals or a conference with a manager. The FTM Appeals Official, serving as a neutral participant, will assist SB/SE and the taxpayer to understand the nature of the dispute and to reach a mutually satisfactory resolution consistent with applicable law. The FTM Appeals Official may also recommend to the parties a resolution on the merits based on the FTM Appeals Official’s analysis of the issues. Either party may withdraw from the mediation process at any time by notifying the other party and the FTM Appeals Official in writing of the withdrawal. The FTM Appeals Official also may terminate the mediation process, by notifying the taxpayer and SB/SE in writing, if it is determined that meaningful progress toward resolution of the issues has stopped. If any issues remain unresolved at the conclusion of FTM, the taxpayer retains all of its otherwise applicable appeal rights.