Effective October 5 2009, the Internal Revenue Service (IRS) has an updated mediation procedure for cases in the Appeals administrative process. Under Revenue Procedure 2009-44, the IRS expands the types of cases eligible for voluntary mediation and clarifies the cases that are ineligible.
Mediation is available for:
- Legal issues.
- Factual issues.
- Certain compliance coordination issues.
- Early referral issues where agreement is not reached.
- Issues for which a request for competent authority assistant has not yet been filed.
- Unsuccessful attempts to enter into a closing agreement.
- Offer in compromise and Trust Fund Recovery Penalty cases.
The new procedure also provides that settlement agreements on mediation cases of $50,000 or more must be reviewed by the Office of Chief Counsel.
Read more here.
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