Overview
Jean Pawlow urged caution for businesses using the new IRS rapid appeals process (RAP), noting that it is possible to “have a situation where you go into RAP and you have a hostile [IRS] examination team and team members who are going to torpedo a settlement.” Ms. Pawlow by contrast urged using the fast-track settlement process, saying that “some practitioners think there’s no reason to try RAP if you have fast-track as an option, because if your exam team is cooperative and willing to engage in negotiations, why not resolve as early as you can, and why move to appeals at all. It’s a good point, and if fast-track is an option, use that.”