The Peck Group LC
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Comprehensive Tax Law Representation Since 1995
We handle every aspect of tax law: preparing tax returns, representing clients during audits, resolving IRS and state tax controversies, and creating tax planning strategies for the future.

Looking at the IRS appeals process and expedited resolution of tax controversies, P.2

On Behalf of | Dec 21, 2016 | IRS |

Previously, we began looking at the IRS appeals process and how the Fast Track Mediation Program fits within that overall process. The IRS appeals process is important because most disputes can be solved through it. Taxpayers do have the right to bypass the appeals process and take their case directly to court, but doing so is often not going to be the most efficient way to handle a tax dispute.

Tax decisions are appealed to local appeals offices, and begin with filing either a small case request or a formal written protest to the contact person identified in the taxpayer’s letter of proposed tax adjustment. Exactly which type of appeal to file depends on the circumstances of the case, including the amount of money in controversy and the number tax periods at issue. Most tax controversies are resolved in small case requests. When more money is at issue, a formal protest is appropriate. 

Fast Track Mediation, again, falls at the earliest stage of the collection process, and involves a trained mediator whose goal is to help the taxpayer and the IRS reach an agreement on dispute issues in the case. In Fast Track Mediation, the taxpayer is not forced to agree to anything.

Certain types of tax cases and issues are not eligible or Fast Track Mediation, and it is important for a taxpayer to carefully consider how the case will be handled if mediation does not solve the issues in the case. Working with an experienced tax attorney is important to navigating these various considerations, as well as tax law and the legal process.


IRS, Appeals Process, Accessed Dec. 12, 2016.

IRS, Fast Track Mediation, Accessed Dec. 12, 2016. 

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