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ARTICLE · 13 OCTOBER 2025

IRS Launches Post-Appeals Mediation Pilot Program: What Taxpayers And Practitioners Need To Know

Farrell Fritz
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The 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.

United StatesLitigation, Mediation & Arbitration
Adam P. Margulies
Adam P. Margulies

The 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.

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