IR-2025-100, Oct. 1, 2025

WASHINGTON — The IRS Independent Office of Appeals is launching a two-year pilot program to make Post Appeals Mediation (PAM) more attractive to taxpayers.

“Appeals is committed to offering Alternative Dispute Resolution programs as a cost-effective option for resolving cases, improving the taxpayer’s experience, and making the best use of IRS resources,” said John Hinding, Acting Chief of Appeals.

Taxpayers can request PAM at the conclusion of an unsuccessful Appeals proceeding, and if the request is accepted, the parties meet in an accelerated mediation session where they make a final attempt to negotiate a mutually acceptable resolution. These sessions usually last one day. They are facilitated by an Appeals mediator with no connection to the underlying case, and taxpayers are invited to include a co-mediator at their own expense. The mediators promote settlement negotiations between the parties while helping them define the issues and identify common ground.

Under the new PAM pilot, cases will be reassigned to an Appeals team unconnected with the underlying case who will represent Appeals in the mediation session. Otherwise, all aspects of PAM will remain the same. This change is not intended to create a new appeal, but instead to facilitate an expedited fresh look at the case in which mediators help the parties explore all potential paths to resolution prior to potential litigation.

“PAM proceedings typically have a high level of success, but we are always working with taxpayers, practitioners, and stakeholders to see how to adjust our ADR programs in ways that make our offerings more desirable for taxpayers and that promote quality tax administration. As a result, the PAM pilot will make a small structural change in the program that we think could have a big impact,” said Michael Baillif, Director of the ADR Program Management Office.

Appeals is continually looking to increase usage of its five ADR programs: Fast Track Settlement, Fast Track Mediation Collection, PAM, the Rapid Appeals Process, and Early Referral in ways that better serve taxpayers and the IRS and contribute to the quick and efficient resolution of tax controversies.

For questions about the PAM pilot, please contact the ADR PMO at ap.adr.programs@irs.gov. For more information about the IRS Independent Office of Appeals, please see Appeals.