A Denver tax lawyer at The McGuire Law Firm recently learned that the IRS Fast Track Settlement (FTS) program will be expanded nationwide. As a tax attorney John McGuire works extremely hard to stay up to date with all IRS notices and publications that may impact our clients. Information regarding the FTS program is stated below.
The FTS Program was designed to help small businesses and the self-employed who are being examined by the IRS. Typically, small business and self-employed individuals would be examined by the division within the IRS called the Small Business/Self Employed Division called the SB/SE Divisions. The goal of the program is to expedite these examinations so small businesses can settle any issues with the Internal Revenue Service quickly.
Generally the FTS Program may be available to taxpayers within the jurisdiction of the SB/SE if:
– The issues are full developed
– A limited number of issues are disputed and thus the majority are agreed upon
– The taxpayer states a written position, or has filed for a small claims request where the total amount of tax liability for any period is $25,000 or less
The FTS Program is not available under the following circumstances and cases:
– Offers in compromise, Trust Fund Recovery Penalty cases, Collection Due Process cases and cases within Collection Appeals
– When certain issues are set to be litigated
– When an issue that would be resolved for one party could result in an inconsistent treatment in the absence of participation from another party
In terms of maintaining and protecting taxpayer rights, which is a concern of our tax attorneys, the program does not inhibit or prevent the taxpayer from exercising their appeal rights if the FTP program is deemed unsuccessful by the taxpayer. The goal of the IRS is to have IRS audit issues resolved within 60 under the FTS Program, as opposed to months or years.
Taxpayers who are under examination will work directly with IRS Agents in the SB/SE area and the IRS appeals office in the FTS Program. It is anticipated that the IRS appeals officer will primarily serve as a mediator. Certain cases can even be fast tracked.
Interested taxpayers or tax attorneys representing taxpayers can contact the examination group manager or specialty program group manager. Form 14017 needs to filed and the taxpayer submits a brief written response to the IRS’ current position.
As a Denver tax attorney, John McGuire has represented many individuals and businesses before the IRS in audit and examination proceedings. We offer a free consultation to discuss your tax issue.