If you have a dispute with the Internal Revenue Service (IRS), the IRS Fast Track program may help you resolve your disagreement more efficiently than an appeal.
Basically, the Fast Track program involves the use of a mediator to help you reach an agreement on disputed issues with the IRS. The program works through the use of a mediator who will work with you and the IRS to broker discussions and possible resolutions between you and the IRS. As an alternative dispute resolution mechanism, mediation is an entirely voluntary process that supports dialogue between the parties. A party to mediation can leave the process at any time and retains their right to appeal the underlying dispute. Unlike an arbitrator, a mediator does not craft a judgment in favor of one party or the other but instead helps both parties find a satisfying means of resolving the dispute.
An application is required for the Fast Track program. You may find the program beneficial in the following instances:
- Collection issues: If you have a disagreement with the IRS over a Trust Fund Recovery or an Offer in Compromise, the Fast Track program may be of help. Using the Fast Track program, the IRS tries to resolve these matters within 40 days.
- International issues: If you are an individual, with a disagreement over international interests during an audit, you can apply for the Fast Track program.
- Non-profits and agency interests: Parties that are tax-exempt or government entities can resolve disputes through the Fast Track program. The IRS aims to resolve these types of disagreements within 60 days.
- Large businesses: During an examination, large businesses, individuals, and businesses with offshore interests can use the program to speed resolution. The time frame for resolving international issues with corporate or individual parties is 120 days.
- Small business interests: Small businesses or self-employed persons can use the Fast Track program to work out disputes. Many of these types of disagreements resolve within 60 days.
Mediation is more often successful when parties at the table have a genuine interest and stake in dispute resolution. The drive behind a mediated issue is not “winning,” but understanding that the position of each party must be represented in a potential resolution.
If you are involved in an IRS audit and dispute the findings of that audit, speak with an experienced tax attorney for help understanding your options. Your attorney can help you with mediation through the Fast Track program.
Contact us when you are challenged by a tax controversy or charged with criminal tax fraud
The tax group at Robert J. Fedor, Esq., LLC helps you respond strategically to questions about taxes, failure to file tax returns, or your FBAR report. We serve local and international clients from offices in Chicago and Cleveland. Call 800-579-0997 or reach out to us today.