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New Fast Track Mediation – Collection Procedure 2016-57

Ron Marini

Revenue Procedure 2016-57 replaces Fast Track Mediation (as outlined in Rev. Proc. 2003-41) with Fast Track Mediation—Collection. Revenue Procedure 2016-57 will be in 2016-49, dated December 5, 2016

Fast Track Mediation—Collection provides taxpayers an opportunity to resolve certain offer-in-compromise and trust fund recovery penalty issues and cases worked by Collection on an expedited basis with an Office of Appeals mediator serving as a neutral party.

Per the IRS, “Consistent with the Internal Revenue Service’s goals of improving service to taxpayers and resolving tax controversies at the earliest opportunity on a fair and impartial basis, in June 2000, the IRS began testing fast track mediation (FTM) procedures for taxpayers who had cases in the Small Business/Self-Employed (SB/SE) Division. Specifically, FTM participants were taxpayers whose cases were being worked in either Examination or Collection, two of SB/SE’s operating units. FTM allowed taxpayers the opportunity to expedite resolution of their cases by mediating their disputes with an Appeals mediator acting as a neutral party.

“As set forth in this revenue procedure, the IRS is replacing FTM with FTMC. Taxpayer requests for FTM have been infrequent throughout the life of the program, and became increasingly so after Fast Track Settlement (FTS) was implemented nationwide. Rather than eliminate FTM, the IRS determined that it would replace FTM with FTMC, which will ensure that taxpayers in Collection continue to be afforded an early opportunity for expedited resolution of their cases via mediation, but limited to certain OIC and TFRP issues and cases worked by Collection.”


Tony Beecher