Document Type
Blog Post
Publication Date
3-18-2026
Abstract
With the 2025 tax return season underway, taxpayers may have dispute resolution options if tax-related disagreements with the IRS occur. Before pursuing litigation, taxpayers can pursue several dispute-resolution options provided by the IRS, including fast track (“FTS”), early referral, and post-appeals mediation. Choosing an appropriate program depends on the status of the disputes and who is currently managing your case. When taxpayers have ordinary unsuccessful appeals negotiations, they can file a request to the IRS Independent Office of Appeals for a non-binding mediation. This will allow a neutral third-party to facilitate conversations between parties without experiencing costly and exhaustive litigation, known as post-appeals mediation (“PAM”).
The print edition of the issue has also been released. This post was originally published on the Cardozo Journal of Conflict Resolution website on March 18, 2026.
Recommended Citation
Qu, Lingxi, "How the IRS Is Trying to Encourage Taxpayer Buy-In Post-Appeal Mediation" (2026). Cardozo Journal of Conflict Resolution (CJCR) Blog. 130.
https://larc.cardozo.yu.edu/cjcr-blog/130
