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Susan Seabrook, Shareholder in Buchanan’s Tax section, discusses new IRS alternative dispute resolution guidance regarding the small business/self-employed fast-track settlement program in Tax Notes’ article “Updates to Fast-Track Settlement Program Draw Concerns.”

Susan E. Seabrook of Buchanan Ingersoll & Rooney PC said the inclusion of the “in the interest of sound tax administration” language isn’t a surprise given the IRS’s use of that phrase in other guidance. Seabrook said her understanding is that the catchall language is intentionally vague and that it makes sense that the government would want to include the provision to protect itself. However, she said it’s unfortunate that taxpayers could be left without recourse if denied access to the FTS program under that provision.