IRS TAX PROBLEMS – What is “Fast Track Mediation” (FTM) in Tax Appeals?




Fast Track Mediation” (FTM) is designed to help Small Business/Self Employed (SB/SE) taxpayers resolve many disputes resulting from Examinations (Audits), Offers in Compromise, Trust Fund Recovery Penalties, and other collection actions while your case stays in SB/SE.

Appeals personnel trained in mediation help you and an IRS representative discuss the issues involved in your disagreement, and possible ways to resolve it. The goal is to reach a jointly agreeable solution, consistent with relevant law, within forty (40) days. The mediator will not require either party to accept a certain outcome.

You and the IRS representative must sign an agreement to Mediate, IRS Form 13369, for your case to be considered for Mediation. You don’t have to file a formal protest to request Fast Track Mediation, but you must provide a written position with your request for Mediation.

Most cases, which are not docketed in any court, qualify for Fast Track Mediation.

Some of the excluded cases are:

  • Issues with no legal precedent;

  • Issues where the courts’ decisions differ

   between jurisdictions;

  • Campus and Automated Collection Service


  • Collection Appeals Program cases; and

  • Those with only frivolous arguments

For Mediation to succeed, all the decision-makers must be present. You may represent yourself at the Mediation session, or you may officially appoint someone to represent you. You can bring anyone you choose to support your position.

You may withdraw from the Mediation process anytime. You retain all the usual appeal rights for any issues that do not get resolved through Fast Track Mediation.