The Internal Revenue Service has announced the nationwide rollout of a streamlined settlement program for small businesses and individuals under examination by the Small Business/ Self-Employed Division of the IRS. Previously, this program was available as a pilot program in only a handful of metropolitan areas across the country.
The program, known as the Fast Track Settlement (FTS) program, is designed to assist small businesses and individuals under examination to save time and avoid formal administrative appeals or litigation. FTS is used to resolve both factual and legal issues, and it provides for Appeals settlement authority while the case is still within the jurisdiction of the Small Business/ Self-Employed examiner.
FTS is available for cases that meet the following requirements:
• Issues are fully developed;
• The taxpayer has stated a position in writing (or filed a small case request for cases in which the total amount for any tax period is less than $25,000, as described in Publication 5, Your Appeal Rights and How To Prepare a Protest If You Don’t Agree); and
• There are a limited number of unagreed issues.
Certain cases are not eligible for FTS, such as Collection Appeals Program cases, Collection Due Process Cases, Offers-In-Compromise, and Trust Fund Recovery Penalty cases. A complete description of the FTS program is set forth in IRS Announcement 2011-05.