ArticleThe IRS Independent Office of Appeals announced a significant update to its alternative dispute resolution (“ADR”) offerings with the launch of a two-year post appeals mediation (“PAM”) pilot program. This initiative, outlined in IRS News Release IR-2025-100, is designed to enhance the existing appeals process, and provide taxpayers with a more effective path to resolution after an unsuccessful appeals proceeding.
What is PAM?
PAM is an ADR tool that allows taxpayers to request mediation after their case fails to settle during the Appeals process. If accepted, both parties engage in a one-day, accelerated mediation session facilitated by a neutral IRS appeals mediator. Taxpayers may also include a co-mediator at their own expense. The goal of PAM is to reach a mutually acceptable resolution, and avoid litigation.
What’s new about the pilot program?
The pilot program introduces a structural change: cases accepted into PAM will now be reassigned to a new appeals team with no prior involvement in the case. This team will represent the IRS during mediation, while offering a fresh perspective and potentially increasing the likelihood of settlement. Importantly, this reassignment is not a new appeal; rather, it’s intended to enhance the existing program to promote impartiality during the mediation process.
John Hinding, Acting Chief of Appeals, emphasized the IRS’s commitment to ADR as a cost-effective and taxpayer-friendly solution. Michael Baillif, Director of the ADR Program Management Office, noted that while PAM already enjoys a high success rate, the pilot program’s structural tweak could yield even better outcomes.
For more information, taxpayers can contact the IRS ADR Program Management Office at ap.adr.programs@irs.gov, or contact a trusted and experienced tax professional.