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IRSA program of post-Appeals mediation has been rolled out nationally by the Internal Revenue Service. The IRS has expanded what had been a pilot program, which was started in December 2008, for Offer in Compromise and Trust Fund Recovery Penalty cases. Aimed at resolving disputes after unsuccessful negotiations with the IRS Office of Appeals, it is available for both factual and legal issues.

The mediator helps the parties in reaching an agreement but does not have settlement authority. Appeals officers trained in mediation techniques will serve as mediators at no cost to taxpayers, who also have the option of paying for a qualified non-IRS co-mediator.

Taxpayers can request nonbinding mediation for eligible cases, but may decline such requests from the IRS. The goal is to complete the process within 90 days of a mediation request's approval.

Criteria and procedures for initiating a post-Appeals mediation request for both examination and collection issues are in Revenue Procedure 2014-63, to published in Internal Revenue Bulletin 2014-53 on Dec. 29, 2014. Most information is available on the Appeals Mediation Programs webpage available on

Last modified on Tuesday, 16 December 2014
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