SECTION 11. POST-SESSION

PROCEDURES

.01 Mediator’s report . At the conclusion of the mediation process, the mediator will prepare a brief written report and submit a copy to each party. See Exhibit 5 of this revenue procedure for a model mediator’s report.

.02 Closing procedures . If the parties reach an agreement on all or some of the issues through the mediation process, Appeals will use established procedures to close the case, including preparation of a Form 906, Closing Agreement on Final Determination Covering Specific Matters . See Statement of Procedural Rules, 26 C.F.R. § 601.106, Delegation Order 236 (Rev. 3) (addressing settlement authority for issues in a Coordinated Examination Program), or § 7122(b) (regarding OIC cases).

If the parties do not reach an agreement on an issue being mediated, Appeals will not reconsider the mediated issue(s), and a statutory notice of deficiency will be issued with respect to all unagreed issues, or

the case will be processed using established closing procedures if there is no deficiency.

.03 Special closing procedures for cer- tain offer-in-compromise cases . For OIC cases with liabilities of $50,000 or more, any settlement or agreement reached through mediation must be reviewed by the Office of Chief Counsel pursuant to section 7122(b) before being finalized. When review is required, Appeals will forward the case to Area Counsel for an opinion as to the legal sufficiency of the offer. See IRM 5.8.8, Offer in Compro- mise, Acceptance Processing, and IRM 8.23.4, Appeals Function, Offer in Com- promise, Acceptance, Rejection Susten- tion, and Withdrawal Procedures for non- Collection Due Process (CDP) Offers .