Fast Track Mediation and Settlement: New IRS Alternative Dispute Resolution Program
Fast Track Mediation Collection (FTMC), Fast Track Settlement (FTS), Post-Appeals Mediation (PAM), and Rapid Appeals Process (RAP)
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This webinar will provide tax professionals with a comprehensive understanding of the available IRS alternative dispute resolution (ADR) techniques. Our astute panel of tax controversy experts will offer procedural and strategic insights into resolving disputes with the IRS efficiently and effectively through the use of ADR.
Outline
- Introduction
- Definition of ADR
- Purpose of the seminar
- Understanding ADR within the context of IRS appeals and litigation
- Background on IRS appeals
- Background on IRS litigation
- General terms and concepts in IRS appeals
- Appeals coordinated issues
- Settlement authority
- Ex-parte communications
- Tax dispute types for which ADR should be considered
- Examination appeals
- Collection appeals
- Innocent spouse relief appeals
- Offer in compromise appeals
- Penalty assessments
- ADR options
- FTMC
- FTS
- PAM
- RAP
- Best practices in IRS ADR
- Preparation for ADR sessions
- Effective communication with the IRS
- Navigating ADR appeals options
- Ethical considerations
Benefits
The panel will cover these and other critical issues:
- Tax dispute types for which ADR should be considered
- Options within ADR including FTM and FTS
- Preparing for ADR sessions
- Effectively communicating with the IRS
Faculty
Michael Baillif
Senior Advisor, Independent Office of Appeals, Director, ADR Program Management Office
IRS Independent Office of Appeals
Mr. Baillif is an attorney serving as Senior Advisor in the Independent Office of Appeals. As part of that role, he is... | Read More
Mr. Baillif is an attorney serving as Senior Advisor in the Independent Office of Appeals. As part of that role, he is the Director of the Alternative Dispute Resolution Program Management Office, which is responsible for centralized administration and innovation of ADR throughout the IRS. Previously, Mr. Baillif worked as Technical Advisor to the National Taxpayer Advocate and specialized in a number of subject areas, including IRS Appeals, tax examinations, international income reporting obligations, and tax penalties of all sorts. He has also served a detail with the IRS Office of Professional Responsibility. With that office, Mr. Baillif conducted disciplinary proceedings and contributed to the revision of Circular 230. He has served as an adjunct professor at the Georgetown University Law Center, teaching courses on ethics and professional responsibilities, income tax accounting, and tax policy. Most recently, Mr. Baillif taught Tax Policy and Fundamentals of Taxation at the University of Baltimore Law School. Over time, he has developed a broad range of experience in the areas of tax law, compliance and risk management, professional services malpractice, conflict resolution, and litigation of various sorts.
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Marcus E. Dyer, CPA, JD
Principal, Team Leader of Tax Controversy
Withum Smith+Brown
Mr. Dyer manages and reviews all aspects of federal and state tax compliance for C-corporation, S corporation and... | Read More
Mr. Dyer manages and reviews all aspects of federal and state tax compliance for C-corporation, S corporation and partnership returns, including consolidated C-corporation returns. He advises businesses on a wide array of tax matters including but not limited to reorganizations and employee benefits. He manages and reviews all aspects of the preparation of high net worth individual returns and conducts tax research on federal and state tax issues. He also handles tax controversies, including at the examination, appeals and collections stages.
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