The IRS said on Wednesday that the Independent Office of Appeals has launched a two-year pilot program to increase awareness of post-appeals mediation, as well as to make it a more attractive option to taxpayers.
Taxpayers can request PAM at the conclusion of an unsuccessful appeals proceeding, and if the request is accepted, the parties meet in an accelerated mediation session where they make a final attempt to negotiate a mutually acceptable resolution.
These sessions usually last one day, accordiing to the IRS, and are facilitated by an appeals mediator with no connection to the underlying case. Taxpayers are allowed to include a co-mediator at their own expense. The mediators promote settlement negotiations between the parties while helping them define the issues and identify common ground.
“Appeals is committed to offering alternative dispute resolution programs as a cost-effective option for resolving cases, improving the taxpayer’s experience, and making the best use of IRS resources,” John Hinding, acting chief of appeals at the IRS, said in a statement on Oct. 1.
Under the new PAM pilot, cases will be reassigned to an appeals team unconnected with the underlying case who will represent the office in the mediation session. Otherwise, all aspects of PAM will remain the same, the IRS said.
The agency added that this change “is not intended to create a new appeal, but instead to facilitate an expedited fresh look at the case in which mediators help the parties explore all potential paths to resolution prior to potential litigation.”
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“PAM proceedings typically have a high level of success, but we are always working with taxpayers, practitioners, and stakeholders to see how to adjust our alternative dispute resolutions programs in ways that make our offerings more desirable for taxpayers and that promote quality tax administration. As a result, the PAM pilot will make a small structural change in the program that we think could have a big impact,” said Michael Baillif, director of the Alternative Dispute Resolution Program Management Office at the IRS.
The Independent Office of Appeals said it’s continually looking to increase usage of its five ADR programs—Fast Track Settlement, Fast Track Mediation Collection, PAM, the Rapid Appeals Process, and Early Referral—in ways that better serve taxpayers and the IRS and contribute to the quick and efficient resolution of tax controversies.
For questions about the PAM pilot, contact ap.adr.programs@irs.gov. For more information about the IRS Independent Office of Appeals, see Appeals.
Photo credit: Pgiam/iStock
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Tags: Income Taxes, IRS, IRS Appeals, tax disputes, Taxes
