LMSB dispute resolution.

• Author: Laffie, Lesli S.
• Position: IRS Large and Mid-Size Business Division

IR-2001-109 describes the IRS's launch of a pilot program to cut the time to resolve corporate-tax disputes. The Large and Mid-Size Business Division (LMSB) Fast Track Dispute Resolution Pilot Program allows corporations to resolve outstanding issues early in the examination process. The pilot is a joint effort between LMSB and Appeals.

Under the program, a taxpayer and LMSB officials can choose between two alternatives: mediation (an Appeals official will seek to facilitate communication and resolve factual issues) or dispute resolution (an Appeals official will recommend a settlement). If the parties decide to use either option, any proposed resolution must be mutually agreed on by both the taxpayer and the LMSB team manager. A corporate taxpayer does not give up any of its appeal or legal rights by participating in the program.

The one-year initiative is intended to test and measure whether an expedited process (to resolve such disagreements within 120 days) reduces cost and time to the government and taxpayers...