Whether an audit or general dispute, dueling with the IRS is expensive and no fun. The expense often arises not from the dispute itself, but from the length of time it takes to resolve it. Simply put, the IRS tends to move slowly when dealing with these issues. For businesses, this means the dispute hangs over you for years with all the accompanying stress and professional expenses you would expect.
The IRS has made an attempt to address this issue through the Fast Track Settlement program. Fast Track is an alternative dispute resolution service approved and arranged by the IRS. The goal of the program is to provide resolutions to issues through a dispute administrator while cutting out the bureaucracy of the agency. From the IRS side of the equation, Fast Track represents a quicker and more efficient method for dealing with disputes, a necessity given budget cutbacks.
The Large and Mid-Sized Business Management and Office of Appeals divisions of the IRS manage the Fast Track program jointly. The program is available for businesses in a dispute with the business management division. It is designed to take place and reach a resolution in 120 days, a very fast pace for tax matters. The process is voluntary. For any decision to be binding on the business and IRS, both parties must agree to a final resolution. In this sense, the process does not replace a trial since the matter is not a final decision unless both parties agree. Ostensibly, the process is designed to address the arguments of both parties and enlighten one or the other to weaknesses in their argument and a like resolution.
Nearly all disputes are available for the Fast Track system. The IRS must approve the use of the dispute, but typically does so. To facilitate your entry into the program, you are required to supply a written statement detailing all of your specific arguments regarding the dispute. Given the fact you have probably already done so at the outset of the dispute, this should not prove to difficult.
