IRS Fast Track Settlement is a voluntary mediation program that can resolve audit disagreements while the examination is still open, instead of waiting for the formal appeals route. A trained official from the IRS Independent Office of Appeals sits down with you and the examiner as a neutral to help both sides reach agreement. For the right dispute, it is designed to reach a resolution much faster than a traditional appeal.
What IRS Fast Track Settlement is
In a standard audit, the examination finishes, you disagree, and only then does the case move to Appeals as a separate step. Fast Track Settlement brings an Appeals official into the audit earlier. For individuals and small businesses, the program runs through the IRS Small Business/Self-Employed division; larger businesses and tax-exempt organizations have their own versions. It is generally available once the issues have been developed but before the examiner issues the letter that closes the audit and offers formal appeal rights.
If you are in an audit that has stalled over one or two issues, call (415) 754-0115 to schedule your free consultation, or send the details through our contact page and we will look at whether this route fits.
How the process works
Both you and the IRS have to agree to participate. Once accepted, a session is scheduled with you or your representative, the examiner, and the Appeals official. Each side explains its view of the disputed issues, and the Appeals official uses mediation techniques, and may offer an evaluation of the issues, to help the parties find common ground. The Appeals official does not impose a decision; any settlement has to be accepted by both you and the IRS.
What the application involves
For small business and self-employed cases, the request is made on Form 14017, the application for Fast Track Settlement, together with a written summary of the issues still in dispute and each side's position. The form is short, but the framing matters: a clear, realistic statement of where the two sides differ signals to the Appeals official that the case is ready to resolve.
Which audits are a good fit
Fast Track tends to work best when the disagreement is about facts or about how settled law applies to specific facts, and when both sides genuinely want to close the case. It is a poorer fit where the facts are still being developed or the dispute turns on an untested legal theory.
Cases that are usually excluded
Not every case qualifies. Matters involving suspected fraud, frivolous positions, listed tax-shelter transactions, and cases already docketed in the Tax Court are generally outside the program, along with certain other issues the IRS designates. Collection disputes, such as levies or payment plans, are handled through different channels. An attorney can judge whether a particular issue is a realistic candidate before a request is made.
How it compares to a traditional appeal
In the standard path, the audit closes with a report, the IRS sends a letter granting the right to appeal, and the case then waits for assignment to an Appeals officer. That sequence is reliable but can take a long time. Fast Track folds an independent perspective into the live audit, while the examiner still has the file and the facts are fresh. To understand the conventional route, our guide to the IRS audit appeals process lays it out step by step.
Appeal rights if there is no agreement
Entering Fast Track does not give up your procedural rights. If the session does not produce an agreement, the audit continues to its normal conclusion, and you can still request a traditional appeal or, after a notice of deficiency, petition the Tax Court. Our article on a Tax Court petition after a notice of deficiency explains that later option.
Why timing matters
Because the program sits inside the examination, the window to use it closes once the examiner wraps up the audit. Examiners do not always raise the option on their own, so the question of whether a case qualifies is best considered while the audit is still open.
Preparing for a session
Preparation is what makes mediation productive. That means a clear written position on each disputed item, the records that support it, and a realistic sense of the strengths and weaknesses on both sides. Mediation is a two-way exercise: an honest view of the weaker parts of a position, not just the strong points, is what allows an Appeals official to help broker an outcome both sides can accept. A focused, well-documented argument generally carries more weight than a loosely organized one.
Help for East Bay taxpayers
The Somal Law Firm in Pleasanton represents individuals and small businesses across the Tri-Valley, Alameda and Contra Costa Counties and the wider East Bay in IRS audits, disputes and appeals. Attorney Bob Somal can evaluate whether Fast Track Settlement suits your audit, prepare a written position, and represent you in the session. See the firm's practice areas, or read how an IRS audit lawyer in the East Bay handles a case from the first letter forward.
Frequently asked questions
Does the Appeals official decide my case?
No. The Appeals official acts as a neutral and helps both sides work toward agreement, but cannot impose a result. Any settlement has to be accepted by you and the IRS.
What happens if we do not settle?
The audit continues as it otherwise would. You still receive the usual examination report and letters and can pursue a traditional appeal or other options available to you.
Can I ask for Fast Track Settlement myself?
Yes. A taxpayer or representative can raise it with the examiner, though both sides must agree to use it and the case must be eligible.
If your audit has stalled and you want to explore resolving it sooner, call (415) 754-0115 to schedule your free consultation. When you get in touch, we will review the disputed issues, explain whether Fast Track Settlement is a realistic option, and discuss how representation through the session would work. You can also reach us through our contact page.
Attorney Advertising. This article is general legal information for Bay Area residents, not legal advice, and does not create an attorney–client relationship. Every situation is different — please consult a licensed attorney about your specific circumstances.