SECTION 2. BACKGROUND

1. Revenue Procedure 2003–40, 2003–1 C.B. 1044, implemented a fast track settlement program for taxpayers in the Large and Mid-Sized Business Division (now the Large Business and International Division). In Announcement 2006–61, 2006–36 I.R.B. 390, the Internal Revenue Service (IRS) implemented a pilot program for fast track settlement for SB/SE taxpayers, relying on the provisions set forth in Rev. Proc. 2003–40. Announcement 2008–110, 2008–48 I.R.B. 1224, and Announcement 2011–5, 2011–4 I.R.B. 430, extended this pilot program and News Release IR–2013–88 announced the nationwide rollout of fast track settlement for SB/SE taxpayers.

2. SB/SE and Appeals jointly administer SB/SE FTS. SB/SE FTS is available to expedite case resolution at the earliest opportunity within the SB/SE Field and Specialty Examination functions. See IRM 1.1.16.3.1, Examination-Field Ar- eas, and IRM 1.1.16.3.3, Specialty- Examination . SB/SE taxpayers that currently have unagreed issues in at least one open year under examination can work together with SB/SE and Appeals to resolve outstanding disputed issues while the case is still in SB/SE jurisdiction and preserve the taxpayer’s ability to request an Appeals hearing. SB/SE FTS can be used to resolve both factual and legal issues, and may be initiated at any time after an issue is fully developed. An issue cannot be fully developed prior to the receipt of all necessary referrals, technical advice, Counsel advice, valuation reports, or other relevant documentation. It is a goal of

SB/SE FTS that the entire process be completed within 60 days after acceptance into the program.