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Published:   |   Last Updated: February 3, 2026

Improve IRS Alternative Dispute Resolution Use and Effectiveness

Objective 10

Background

The IRS’s Alternative Dispute Resolution (ADR) programs offer a unique opportunity for taxpayers to expedite the administrative resolution of their tax disputes, provide finality, and eliminate the burden and need for costly litigation. The IRS designed the ADR programs to save taxpayers and the government time and resources and ensure the protection of taxpayer rights. However, a 65 percent decline in taxpayer use of ADR between Fiscal Years 2013 and 2022 reveals significant agency shortcomings and an urgent need to understand the reasons for this decline. The National Taxpayer Advocate previously recommended the IRS revitalize its ADR programs and ensure they serve as efficient, accessible, and transparent mechanisms for resolving tax disputes to uphold and advance taxpayer rights. To its credit, on April 24, 2024, the IRS announced the creation of an ADR Program Management Office within the Independent Office of Appeals (Appeals) to revamp its ADR offerings.

Highlights

1
1.

Status

2
2.

Activities

Activity 1: Establish a cross-functional team consisting of TAS and the Appeals’ ADR Program Management Office to develop strategies to improve and promote ADR programs.

Activity 2: Participate in cross-functional team meetings to ensure eligible taxpayers have awareness of and the opportunity for ADR.

Activity 3: Propose collaborative meetings with Appeals’ ADR Program Management Office to develop and deploy a robust IRS-wide data collection and analysis framework. This framework should include taxpayer requests for ADR, denials, and outcomes for each ADR option (e.g., Fast Track Settlement, Fast Track Mediation, Post Appeals Mediation) across all stages of the administrative dispute resolution cycle, focusing on improving transparency, identifying trends, and addressing program shortfalls.

Activity 4: Advocate for the creation and implementation of a specialized unit within the IRS dedicated to ADR and focused exclusively on mediating tax disputes early in the process and participate in collaborative ADR cross-functional program meetings.

Activity 5: Propose collaborative meetings with Appeals’ ADR Program Management Office to establish guidance to lower ADR participation barriers.

Activity 6: Propose collaborative meetings to allow TAS to participate in the creation of ADR training for Appeals technical employees.

Activity Update:

Activity 1: TAS established a recurring quarterly discussion with Appeals’ Alternative Dispute Resolution (ADR) Office to find opportunities to promote the ADR programs, lower ADR participation barriers, and increase taxpayers’ awareness of ADR opportunities. To support these efforts, Systemic Advocacy has developed a draft addition to the Get Help/TAS Roadmap and formulated ideas for incorporating relevant language to assist Case Advocates. The ADR office has agreed to develop new mediator training. Both TAS Systemic Advocacy and the ADR office are collaboratively exploring the potential for a research study aimed at investigating possible expansion of the ADR program. This activity is being closed as completed.

Activity 2: TAS Systemic Advocacy and Appeals ADR office held two meetings during 4th quarter to continue discussing ways TAS can assist IRS in expanding and tracking data in the ADR programs. Several BODs finalized guidance in 4th quarter explaining how the ADR programs will be tracked. This data collected regarding the requests, use and outcome of the programs will enable the IRS to identify possible areas of improvement in the ADR programs moving forward. This activity is being closed as completed.

Activity 3: N/A

Activity 4: N/A

Activity 5: TAS Systemic Advocacy and Appeals ADR office held two meetings during 4th quarter to continue discussing ways TAS can assist IRS in lowering ADR participation barriers to allow more taxpayers to take advantage of the benefits. Building on the success of the LBI Fast-Track Settlement Pilot introduced in FY25 2nd quarter, the IRS announced a Post Appeals Mediation Pilot in the 4th quarter. These pilot programs reduce participation barriers, allowing more taxpayers the ability to take advantage of the Appeals ADR programs. This activity is being closed as completed.

Activity 6: TAS Systemic Advocacy and Appeals ADR office held two meetings during 4th quarter in which TAS to help in the creation of ADR training. Appeals ADR office was able to revamp some prior training and update it regarding Post Appeals Mediation and a Mediator refresher course. This activity is being closed as completed.

3
3.

1st Quarter Actions Completed

The Taxpayer Advocate Service (TAS) Systemic Advocacy (SA) met with the Office of Appeals Alternative Dispute Resolution (ADR) Program Management Office and discussed ideas and strategies to improve and promote ADR programs, lower ADR participation barriers, and increase taxpayer awareness of ADR opportunities.

The Taxpayer Advocate Service (TAS) has formed a collaborative team to meet regularly with the Office of Appeals Alternative Dispute Resolution (ADR) Office to discuss various ADR ideas and issues including TAS participation in ADR training development and participation in data collection and analysis framework creation.

4
4.

2nd Quarter Actions Completed

TAS established a recurring quarterly discussion with Appeals’ Alternative Dispute Resolution (ADR) office to find opportunities to promote the ADR programs, lower ADR participation barriers, and increase taxpayers’ awareness of ADR opportunities. TAS advocated for the IRS Independent Office of Appeals Alternative Dispute Resolution (ADR) Program Management Office to establish a data collection mechanism for ADR denials and outcomes. ADR took action to establish a data collection mechanism to track denials and ADR outcomes. The IRS Independent Office of Appeals Alternative Dispute Resolution (ADR) Program Management Office established a data collection mechanism for all items related to ADR and stood up the ADR Program Management Office. TAS has established a recurring quarterly discussion with Appeals’ Alternative Dispute Resolution (ADR) office to find opportunities to promote the ADR programs, lower ADR participation barriers, and increase taxpayers’ awareness of ADR opportunities.

5
5.

3rd Quarter Actions Completed

TAS established a recurring quarterly discussion with Appeals’ Alternative Dispute Resolution (ADR) Office to find opportunities to promote the ADR programs, lower ADR participation barriers, and increase taxpayers’ awareness of ADR opportunities. To support these efforts, Systemic Advocacy has developed a draft addition to the Get Help/TAS Roadmap and formulated ideas for incorporating relevant language to assist Case Advocates. The ADR office has agreed to develop new mediator training. Both TAS Systemic Advocacy and the ADR office are collaboratively exploring the potential for a research study aimed at investigating possible expansion of the ADR program.

6
6.

4th Quarter Actions Completed

TAS established a recurring quarterly discussion with Appeals’ Alternative Dispute Resolution (ADR) Office to find opportunities to promote the ADR programs, lower ADR participation barriers, and increase taxpayers’ awareness of ADR opportunities. To support these efforts, Systemic Advocacy has developed a draft addition to the Get Help/TAS Roadmap and formulated ideas for incorporating relevant language to assist Case Advocates. The ADR office has agreed to develop new mediator training. Both TAS Systemic Advocacy and the ADR office are collaboratively exploring the potential for a research study aimed at investigating possible expansion of the ADR program.

TAS Systemic Advocacy and Appeals ADR office held two meetings during 4th quarter to continue discussing ways TAS can assist IRS in expanding and tracking data in the ADR programs. Several BODs finalized guidance in 4th quarter explaining how the ADR programs will be tracked. This data collected regarding the requests, use and outcome of the programs will enable the IRS to identify possible areas of improvement in the ADR programs moving forward.

(TAS continues to offer assistance, but the “tracking” of most ADR programs lies with the BODs. Some BODs have developed interim procedures, SBSE is still working on. This is not an activity that BODs/Appeals want/need help with. We won’t be pursuing this activity in FY26).

TAS Systemic Advocacy and Appeals ADR office held two meetings during 4th quarter to continue discussing ways TAS can assist IRS in lowering ADR participation barriers to allow more taxpayers to take advantage of the benefits. Building on the success of the LBI Fast-Track Settlement Pilot introduced in FY25 2nd quarter, the IRS announced a Post Appeals Mediation Pilot and in 4th quarter. These pilot programs reduce participation barriers, allowing more taxpayers the ability to take advantage of the Appeals ADR programs.
(Recommend closing this activity. There are no Appeals ADR SAOs for FY26. Team is still seeing if we can do an ADR research study – during FY26 or maybe FY26 ARC but it is unclear if the research project will come to fruition.

TAS Systemic Advocacy and Appeals ADR office held two meetings during 4th quarter in which TAS to help in the creation of ADR training. Appeals ADR office was able to revamp some prior training and update it regarding Post Appeals Mediation and a Mediator refresher course.

(Recommend closing this activity. Appeals ADR PMO wants to do their own training they do not want TAS assisting. We won’t be pursuing this activity in FY26).