The Internal Revenue Service released a revenue procedure Friday providing rules for the nationwide rollout of post-appeals mediation for both Offer in Compromise and Trust Fund Recovery Penalty cases.

The IRS Office of Appeals originally launched post-appeals mediation for both types of cases as a pilot program that was available in certain cities in December 2008 and is now expanding the program nationwide.

Post-appeals mediation is available to help resolve disputes after unsuccessful negotiations with the IRS Office of Appeals and is available for both factual and legal issues. The mediator’s role is to help the parties reach their own agreement collaboratively, but the IRS noted that the mediator does not have settlement authority over any issue. Appeals officers trained in mediation techniques will serve as mediators at no cost to taxpayers, however. Taxpayers also have the option of paying for a qualified non-IRS co-mediator.
Taxpayers or the IRS Office of Appeals are able to request nonbinding mediation for eligible cases, but the taxpayer can decline the IRS Office of Appeals’ request for mediation. The goal is to complete the process within 90 days after the mediation request is approved.

Eligibility criteria and complete procedures for initiating a post-appeals mediation request for both examination and collection issues are in Revenue Procedure 2014-63, which will be published in Internal Revenue Bulletin 2014-53 on Dec. 29, 2014.

For more information on post-appeals mediation, visit the Appeals Mediation Programs page on

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