SECTION 5. SETTLEMENT PROCESS

.01 FTS employs various alternative dispute resolution techniques to promote agreement. An FTS Appeals Official will serve as a neutral party. The FTS Appeals Official will not perform in a traditional Appeals role, but will use dispute resolution techniques to facilitate settlement between the parties. An Appeals Team Case Leader, trained in mediation or, in limited cases, an Appeals Officer, trained in mediation, in conjunction with an Appeals Team Manager, will serve as the neutral FTS Appeals Official.

.02 During FTS, the taxpayer and LMSB representatives, including at least one representative with decision-making authority, from both LMSB and the taxpayer, will meet with the FTS Appeals Official. The taxpayer and LMSB representatives should include individuals with the information and expertise necessary to assist the parties and the FTS Appeals Official during the settlement process. The FTS Appeals Official may ask the parties to limit the number of participants to facilitate the process. Any person engaged in practice before the Ser

shall be subject to the procedures that would be applicable if the issue were being considered by Appeals, including procedures in the Internal Revenue Manual and existing published guidance. FTS therefore creates no special authority for settlement by the FTS Appeals Official. For example, if the FTS issue is coordinated in either the Technical Advisor Program or the Appeals Technical Guidance program, the proposed settlement of that issue is subject to established procedures, including submission of the proposed settlement to the Appeals Coordinator for review and concurrence