1. Introduction: What is Form 14017?

IRS Form 14017, officially titled the Application for Fast Track Settlement, is an administrative alternative dispute resolution (ADR) document published by the Internal Revenue Service (IRS). The IRS is a bureau of the United States Department of the Treasury responsible for administering the federal tax code and conducting compliance audits.

Unlike personal tax returns or routine payment schedules, Form 14017 is an audit dispute resolution form. It is operated collaboratively between IRS Examination divisions—such as Small Business/Self-Employed (SB/SE), Large Business and International (LB&I), and Tax Exempt and Government Entities (TE/GE)—and the IRS Independent Office of Appeals.

When an audit results in unresolved disagreements, traditional administrative appeals can take a year or more to conclude. Form 14017 serves as the formal joint application that allows an audited taxpayer and the IRS audit team to bring in an impartial Appeals Officer to mediate and settle the dispute within 60 to 120 days, all while the case remains under the jurisdiction of the examination division.

2. Purpose of the Form

During a tax examination, an auditor may propose adjustments—such as disallowing business expenses, reclassifying workers, or adjusting corporate income—that the taxpayer strongly disputes. Under standard audit procedures, resolving these disputes requires waiting for the audit to close, receiving a formal 30-Day Letter, preparing an extensive written legal protest, and waiting in line for a traditional appeals conference.

The Fast Track Settlement (FTS) program was created to eliminate this costly bureaucratic delay. Form 14017 initiates an expedited settlement process that takes place directly at the examination level, bypassing the need for a formal written protest or prolonged administrative waiting periods.

What makes Form 14017 unique is that the neutral Appeals Officer assigned to the session holds formal settlement authority. Unlike basic mediation, the Appeals mediator in a Fast Track Settlement can evaluate the “hazards of litigation”—the probability of what would happen if the case went to court—and propose a binding compromise that both the taxpayer and the IRS examination team can accept on the spot.

3. Who Needs to File This Form

Form 14017 is a joint application completed by taxpayers and IRS audit personnel who have reached an impasse during an active examination. You may use this form if you represent or belong to any of the following groups:

Small Businesses and Self-Employed Individuals (SB/SE): Sole proprietors, partnerships, and small corporations undergoing field or office examinations where factual or legal issues remain unagreed.
Large Corporate & International Businesses (LB&I): Mid-size to multinational corporations seeking an expedited resolution of complex corporate or international tax adjustments.
Tax-Exempt & Government Entities (TE/GE): Non-profit charities, private foundations, employee retirement plans, and tribal governments with unagreed audit findings.
Tax Representatives: Certified Public Accountants (CPAs), Enrolled Agents (EAs), and tax attorneys holding an active Form 2848 power of attorney who want to resolve client audits quickly.

Filing requires mutual consent. Both the taxpayer (or authorized representative) and the IRS Examination Group Manager must agree to participate and sign Form 14017.

4. Who Is Exempt / Not Required to File

Because Form 14017 is strictly an elective dispute resolution tool for specific active audits, most taxpayers and tax issues are exempt or barred from using it:

Agreed Audit Cases: If you agree with the examiner’s findings, you do not use Form 14017; you simply sign the examination agreement (such as Form 4549 or Form 870) and close the audit.
Collection-Only Disputes: Taxpayers disputing liens, levies, or rejected Offers in Compromise do not use Form 14017; they use collection appeal tools like Form 13369 or Form 12153.
Frivolous Issues: The IRS strictly excludes constitutional arguments, tax-protester claims, or positions lacking legal merit.
Cases Already in Traditional Appeals or Tax Court: If the IRS has already issued a formal 30-Day Letter or a 90-Day Statutory Notice of Deficiency, or if a petition has been filed in the U.S. Tax Court, Fast Track Settlement is no longer available.
Whipsaw Issues: Disputes where resolving the issue with one taxpayer could lead to inconsistent tax results for another party (such as alimony disputes between former spouses) are excluded.
Criminal Investigations: Any case involving suspected criminal tax fraud is legally barred from alternative dispute resolution.

5. When to File

Form 14017 operates within a specific window during the lifecycle of an IRS audit:

After Issues Are Fully Developed: You must request Fast Track Settlement only after all documents, bank records, and legal arguments have been fully exchanged and evaluated by the auditor.
After Manager Conference: For SB/SE taxpayers, you must first participate in an informal conference with the examiner’s Group Manager before an FTS application will be approved.
Before Formal Deficiency Notices: Form 14017 must be submitted before the IRS issues a formal 30-Day Letter or a 90-Day Statutory Notice of Deficiency.
Sufficient Statute of Limitations: There must be enough time remaining on the assessment statute of limitations (typically at least 120 to 150 days); taxpayers with expiring deadlines must agree to extend the statute using Form 872.

Once accepted into the program, the goal is to resolve SB/SE and TE/GE disputes within 60 calendar days, and LB&I corporate cases within 120 calendar days.

6. Where and How to File

Form 14017 cannot be filed through commercial tax software like TurboTax. It is an administrative document handled jointly between the taxpayer and the IRS examination team.

You do not mail Form 14017 directly to the IRS Independent Office of Appeals on your own. Instead, you and your IRS revenue agent complete the form together. The agent forwards the signed application to the IRS Examination Group Manager for review and approval.

Once approved by IRS management, the Group Manager transmits the complete FTS package—including Form 14017, the examiner’s proposed adjustments, and your written position statement—electronically to the Appeals Alternative Dispute Resolution Program Management Office. If physical records are exchanged, documents are delivered to the specific IRS address as per instructions on your examination correspondence.

7. Step-by-Step Instructions to Fill the Form

Form 14017 is a concise, one-page application designed to outline the parties, the unagreed tax periods, and the session participants. Review the table below for a section-by-section guide.

Section	Required Information	Instructions for Applicants
Header	Submission Tracking	Completed by IRS personnel to record the submission date, Appeals office location, and originating division (SB/SE, LB&I, or TE/GE).
Taxpayer Profile	Taxpayer & Tax Details	Enter the type of tax (Income, Employment, Excise), legal taxpayer name, Social Security Number (SSN) or EIN, tax years under review, and address.
Representative	Authorized Practitioner	Provide the name, firm name, address, phone, and fax of your CPA, Enrolled Agent, or attorney, and verify Form 2848 is attached.
Examination Group	IRS Team Information	Record the name, title, physical office address, phone, and fax number of the assigned IRS revenue agent and Group Manager.
Session Participants	Attendee Roster	List the legal names, job titles, and phone numbers of every person who will attend the settlement session (must have settlement authority).
Terms & Disclosures	Statutory Consents	Review legal clauses consenting to tax return disclosure under Section 6103(c) and waiving ex parte communication restrictions.
Signatures	Bilateral Execution	Signed and dated by the taxpayer, spouse (if joint), authorized representative, IRS Group Manager, and approving division executive.

Understanding the Statutory Disclosures on Form 14017

When you sign Form 14017, you agree to two specific legal conditions that enable the mediation process to function:

Section 6103(c) Disclosure Consent: You authorize the IRS to disclose confidential tax returns and return information related to the disputed issues to all technical experts, accountants, and participants listed on the form.
Ex Parte Communications Waiver: Under Section 1001(a) of the IRS Restructuring and Reform Act of 1998, Appeals officers are normally barred from speaking with IRS examiners without the taxpayer present. By signing Form 14017, you waive this restriction for the Fast Track session, allowing the mediator to speak candidly with both sides to broker a compromise.

8. Required Documents/Information Needed Before Filling

Submitting Form 14017 requires a complete documentation package known as the FTS Submission Package. Before finalizing the form, assemble the following records:

The Proposed Adjustments: A copy of Form 5701 (Notice of Proposed Adjustment), Form 886-A (Explanation of Items), or the draft Revenue Agent’s Report (RAR) detailing the auditor’s calculations.
Taxpayer’s Written Position Statement: A clear, organized written narrative explaining the factual and legal grounds for your disagreement with each disputed item.
Form 2848 (Power of Attorney): A signed authorization form confirming your CPA, Enrolled Agent, or attorney is authorized to represent you before both Examination and Appeals.
Statute Extension (if needed): A signed Form 872 extending the assessment statute of limitations if fewer than 120 to 150 days remain before expiration.
Proof of Decision-Making Authority: Corporate resolutions or authorizations confirming that attendee representatives hold full legal authority to settle the tax liability.

9. Common Mistakes to Avoid

Fast Track Settlement operates under strict procedural guidelines. Avoid these frequent mistakes that can cause your application to be rejected:

Submitting Without Group Manager Approval: You cannot submit Form 14017 independently. It is a joint application that must be approved and signed by the IRS Examination Group Manager.
Introducing Brand-New Information: Fast Track Settlement is strictly for issues where all facts have already been audited. Attempting to bring unreviewed bank statements or surprise deductions to the session will result in immediate termination of the FTS process.
Missing Statute of Limitations Deadlines: The IRS will not accept an FTS application if the statute of limitations is set to expire shortly, unless you agree to an extension.
Bringing Representatives Without Settlement Authority: The corporate officer or taxpayer attending the session must have the legal authority to accept a financial settlement on the spot.
Mistaking the Mediator for a Judge: The Appeals Officer cannot force either you or the IRS audit team to accept an offer. If either side refuses the recommended settlement, the process ends.

10. Penalties for Non-Filing or Errors

Because Form 14017 is a voluntary alternative dispute resolution application, there are no civil tax penalties, fines, or late fees for choosing not to apply. However, passing on Fast Track Settlement carries practical consequences:

Forfeiture of Fast-Track Resolution: Bypassing FTS means your audit will close unagreed, requiring you to wait for a 30-Day Letter, draft a formal written protest, and wait 6 to 18 months for a traditional appeals conference.
Continuing Interest Accrual: Because FTS does not pause statutory interest calculations, longer disputes result in higher overall debt balances if adjustments are ultimately upheld.
Full Retention of Traditional Appeal Rights: If you participate in FTS and cannot reach an agreement, you do not lose anything. You retain 100% of your traditional appeal rights, including the right to receive a 30-Day Letter, file a formal protest, or petition the U.S. Tax Court.
Perjury and False Statements Liability: Written statements and documentation submitted with Form 14017 are federal submissions subject to 18 U.S.C. Section 1001, carrying criminal penalties for intentional misrepresentation.

11. Related Forms or Schedules

Form 14017 operates within a specialized network of IRS audit, appeal, and dispute resolution forms:

Form 5701: Notice of Proposed Adjustment (NOPA)
Form 886-A: Explanation of Items (detailed audit adjustments)
Form 4549: Income Tax Examination Changes (standard audit report)
Form 870: Waiver of Restrictions on Assessment and Collection of Deficiency in Tax
Form 906: Closing Agreement on Final Determination Covering Specific Matters
Form 872: Consent to Extend the Time to Assess Tax
Form 2848: Power of Attorney and Declaration of Representative
Form 13369: Agreement to Mediate (Fast Track Mediation for collection cases)
Publication 5022: Fast Track Settlement for SB/SE Taxpayers
Publication 5092: Fast Track Settlement for TE/GE Taxpayers
Publication 4167: Introduction to Alternative Dispute Resolution

12. Frequently Asked Questions

What is the difference between Fast Track Settlement (FTS) and Fast Track Mediation (FTM)?

Fast Track Settlement applies to active tax audits and uses an Appeals Officer who holds settlement authority based on the hazards of litigation. Fast Track Mediation is typically used in collection disputes (such as Offers in Compromise) where the mediator facilitates discussion but cannot independently recommend a hazards-of-litigation settlement.

Can the Appeals Officer force the IRS examiner to settle?

No. The Appeals Officer acts as a neutral facilitator who evaluates both sides and proposes a settlement. However, both the taxpayer and the IRS Examination Group Manager must voluntarily agree to the proposed terms; the mediator cannot impose a decision.

What happens if we cannot reach an agreement during Fast Track Settlement?

If you reach an impasse and FTS concludes without an agreement, your case returns to standard audit processing. The examiner will issue a 30-Day Letter, and you can exercise your full traditional appeal rights by submitting a formal written protest to the Independent Office of Appeals.

Can either party withdraw from Fast Track Settlement after signing Form 14017?

Yes. Participation in FTS is completely voluntary. Either the taxpayer or the IRS examination team may withdraw from the process at any time before reaching a signed settlement by providing written notice.

How long does the Fast Track Settlement session itself take?

Most FTS sessions are completed in a single day, typically lasting between two and six hours. Depending on geographic location and scheduling, sessions may take place in person at an IRS office or virtually via secure video conference.

Does submitting Form 14017 stop interest from compounding?

No. Participating in FTS does not pause statutory interest. However, because FTS resolves audits in 60 to 120 days rather than the one to two years common in traditional appeals, it substantially reduces the total interest that can accrue on the final settled balance.

13. Conclusion: Key Takeaways Summarized

IRS Form 14017 provides an expedited, collaborative off-ramp to resolve difficult tax audits without prolonged administrative battles. Keep these primary points in mind:

Expedited Audit Resolution: Form 14017 initiates Fast Track Settlement, designed to resolve unagreed audit issues within 60 to 120 calendar days.
Appeals Settlement Authority: The Appeals mediator evaluates the hazards of litigation and can propose compromise settlements directly at the audit level.
Bilateral Consent Required: Both you and the IRS Examination Group Manager must agree to participate and sign the form.
Full Facts Must Be Developed: All documents, receipts, and legal arguments must be exchanged before submitting the application.
Preserves Full Appeal Rights: If Fast Track Settlement does not produce an agreement, you retain 100% of your rights to a traditional appeal and Tax Court review.
Submit with Your Audit Team: Deliver your completed application and written position directly to your IRS revenue agent as per instructions on your examination notice.

IRS Form 14017 Guide: Fast Track Settlement Rules & Steps