Announcement 2025-6

This announcement describes a pilot program testing changes to Fast Track Settlement (FTS) programs currently available to taxpayers under examination in the Large Business and International (LB&I), Small Business/Self-Employed (SB/SE), and Tax Exempt/Government Entities (TE/GE) operating divisions (collectively, Exam).

FTS enables taxpayers that have unagreed issues in at least one open taxable year under examination to work together with Exam and the IRS Independent Office of Appeals (Appeals) to resolve outstanding disputed factual and legal issues while the case is still in Exam’s jurisdiction. LB&I, SB/SE, and TE/GE each jointly administer FTS with Appeals. FTS is optional for taxpayers and does not eliminate or replace existing dispute resolution options, including taxpayers’ opportunities to request Appeals consideration or a conference with an Exam manager.

This announcement also describes pilot program changes to Post Appeals Mediation (PAM) procedures and introduces a “Last Chance FTS” pilot program for SB/ SE taxpayers.

BACKGROUND

FTS began as a pilot program in 2001 with the goal of successfully using dispute resolution techniques to promote issue resolution at earlier stages. See Notice 2001-67, 2001-2 C.B. 544 (December 3, 2001). In 2003, the IRS formally established FTS for taxpayers under the jurisdiction of the Large and Mid-Size Business division, a predecessor to LB&I. The IRS also allowed the use of Appeals’ alternative dispute resolution (ADR) settlement authority in certain cases under the jurisdiction of SB/SE. See Rev. Proc. 2003-40, 2003-25 I.R.B. 1044 (June 23, 2003). In 2012, the IRS permanently established the FTS program for taxpayers under the jurisdiction of TE/GE. See