IRS Fast Track & Mediation

What Is IRS Fast Track Settlement?

IRS Fast Track Settlement is a voluntary dispute resolution program administered by the IRS Independent Office of Appeals that allows taxpayers and IRS examiners to resolve open issues during the examination process — before the case ever leaves the audit division.

Unlike the standard appeals process — which requires the examination to conclude, a Notice of Deficiency to be issued, and a formal protest to be filed — Fast Track Settlement brings an Appeals Officer into the examination as a mediator while the audit is still open. The goal is to resolve disputed issues more quickly and efficiently than the traditional administrative process allows.

Fast Track Settlement is available for:

• Small Business and Self-Employed taxpayers — through the SB/SE Fast Track Settlement program

• Large Business and International taxpayers — through the LB&I Fast Track Settlement program

• Campus examination cases — through the Campus Fast Track Settlement program

The program is voluntary for both the taxpayer and the IRS examiner — meaning both parties must agree to participate. But when it is available and appropriate, Fast Track Settlement can resolve a dispute in as little as 60 days — compared to the months or years that standard examination and appeals processes can take.

What Is IRS Fast Track Mediation?

IRS Fast Track Mediation is a separate program — available specifically for collection and Offer in Compromise cases — that provides taxpayers with access to a neutral IRS mediator to help resolve disputes that have arisen during the collection process.

Fast Track Mediation is available when:

• An Offer in Compromise has been rejected and the taxpayer disagrees with the rejection

• A collection alternative — such as an installment agreement or currently not collectible status — has been denied

• A Trust Fund Recovery Penalty has been proposed and the taxpayer disputes the determination

• Other collection issues have reached an impasse that cannot be resolved through normal channels

Like Fast Track Settlement, Fast Track Mediation is designed to provide a faster, less adversarial path to resolution than formal administrative appeals — and it can produce outcomes that neither party could achieve through the standard process.

Post Appeals Mediation

For cases that have already gone through the Appeals process without reaching a satisfactory resolution, the IRS offers Post Appeals Mediation — a program that provides one final opportunity to resolve a dispute through mediation before litigation becomes the only remaining option.

Post Appeals Mediation is available after an Appeals conference has concluded without agreement and before a statutory notice is issued. It involves a neutral mediator — typically an Appeals Officer with no prior involvement in the case — who facilitates a structured negotiation between the taxpayer and the IRS with the goal of reaching a mutually acceptable resolution.

At Blackridge Tax, we evaluate Post Appeals Mediation as a strategic option in every case that has reached the Appeals level without resolution — because in the right circumstances it can produce outcomes that litigation cannot guarantee and at a fraction of the cost and time.

Why Fast Track Programs Matter for Your Case

The traditional path through an IRS dispute — examination, notice, protest, appeals conference, potential litigation — can take years. During that time penalties and interest continue to accrue. Collection activity may continue. And the uncertainty of an unresolved dispute creates ongoing financial and operational stress for the taxpayer.

Fast Track Settlement and mediation programs exist specifically to address this problem — to provide a faster, less adversarial, and often more cost-effective path to resolution for disputes that are genuinely resolvable but have reached an impasse through normal channels.

For taxpayers with significant disputes involving defensible positions — where the IRS's determination is factually or legally incorrect but litigation would be disproportionately expensive or uncertain — Fast Track programs can be the most strategically sound resolution path available.

The key advantages of Fast Track Settlement and mediation:

• Speed — resolution in weeks or months rather than years

• Cost efficiency — significantly lower than litigation in Tax Court or federal district court

• Preserved relationships — a negotiated resolution avoids the adversarial dynamic of formal litigation

• Flexibility — mediators have broader settlement authority than examiners and can consider the overall facts and circumstances rather than applying rigid legal standards

• Certainty — a negotiated settlement produces a defined, final outcome rather than the uncertainty of a court decision

When Fast Track Is — and Is Not — Appropriate

Like every resolution tool, Fast Track Settlement and mediation are not universally appropriate. They are most effective when:

• The dispute involves a specific, defined issue — a deduction, a valuation, a classification — rather than a systemic pattern of non-compliance

• The taxpayer has a genuinely defensible position that has merit but faces uncertainty in formal proceedings

• Both parties have an interest in resolving the dispute efficiently rather than pursuing a protracted administrative or judicial process

• The amount in dispute is significant enough to warrant the investment in the process but not so large that the risk profile favors litigation

They are generally not appropriate when:

• The IRS's position is legally correct and the taxpayer's only goal is to delay resolution

• The case involves fraud, criminal conduct, or other issues that fall outside the scope of civil dispute resolution

• The taxpayer's position has no genuine merit and the goal is simply to negotiate a reduction

At Blackridge Tax, we evaluate every case honestly — and we recommend Fast Track Settlement or mediation only when the facts and circumstances genuinely support it. When they do, we pursue it with the same preparation and strategic discipline we bring to every engagement.

The Role of Representation in Fast Track Proceedings

Fast Track Settlement and mediation are not informal conversations. They are structured legal proceedings — and the quality of the representation brought to them has a direct impact on the outcome.

At Blackridge Tax, we prepare for every Fast Track proceeding with the same rigor we bring to formal litigation — developing a comprehensive presentation of the facts, the applicable law, and the specific arguments that support our client's position. We know how Appeals Officers and mediators evaluate cases. We know what arguments are persuasive in this context and what evidence is most effective. And we know how to negotiate toward an outcome that our clients can accept — without leaving value on the table.

The Blackridge Standard

Blackridge Tax evaluates IRS Fast Track Settlement and mediation as resolution options for clients facing significant federal tax disputes involving $50,000 or more in contested liability. Our team includes a Board Certified Tax Specialist, attorneys licensed in six states and before the U.S. Tax Court, a CPA, and an Enrolled Agent — professionals who understand both the technical requirements of these programs and the strategic considerations that determine whether they are the right path for each client's specific situation.

The most powerful resolution is sometimes the one that never required a fight. Knowing when to negotiate — and how — is what separates a good outcome from a great one.