SECTION 6. POST-SESSION

PROCEDURE

.01 Unless specific conditions warrant altering the agreement, e.g., a subsequent authoritative decision that materially alters the basis for the agreement, the basis of settlement shall not be modified after the FTS Session Report is signed. Nor may either party raise a new issue for FTS consideration after the FTS Session Report is signed unless both parties and the FTS Appeals Official agree. New issues not accepted for consideration under FTS may still be raised and considered outside the FTS program.

.02 After the parties and the FTS Appeals Official sign the FTS Session Report acknowledging a basis of settlement, the FTS Appeals Official will draft the appropriate settlement document to reflect the agreed upon treatment of the issue. The FTS Appeals Official may use delegated settlement authority to enter into and approve any Fast Track settlement agreement ( e.g., specific matter closing agreement or Form 870– AD). Alternatively, LMSB and the taxpayer may resolve an issue using LMSB resolution authority and LMSB will include the issue as an agreed issue in the Revenue Agent’s Report. LMSB will then close the case using established case closing procedures.

.03 If one or more issues remain unsettled at the end of FTS, the FTS Appeals Official will send a letter to both the taxpayer and LMSB, stating who participated in the program, listing any unresolved issues, and explaining the taxpayer’s rights to appeal unresolved issues.