IRS Launches Two-Year Post Appeals Mediation (PAM) Pilot Program
Posted in Offshore Account Update on November 28, 2025 | Share
The Internal Revenue Service (IRS) recently announced that it is launching a two-year pilot program under its existing Post Appeals Mediation (PAM) procedure. According to the IRS, this pilot program should make PAM “more attractive to taxpayers,” and the Director of the IRS’ ADR Program Management Office has stated that he anticipates the pilot program will lead to more negotiated resolutions following unsuccessful appeals. Here are some insights for taxpayers who may be considering PAM from Washington D.C. tax attorney Kevin E. Thorn, Managing Partner of Thorn Law Group:
When Can (and Should) Taxpayers Pursue Post Appeals Mediation (PAM)?
Post Appeals Mediation (PAM) is an option for taxpayers who have unsuccessfully challenged unfavorable IRS audit determinations before the IRS' Independent Office of Appeals (“Appeals”). Taxpayers who opt to pursue PAM have the opportunity to negotiate their tax liability with the IRS with the assistance and oversight of an Appeals mediator. The Appeals mediator “[has] no connection to the underlying case,” and his or her role is to try to help facilitate a mutually agreeable resolution.
Mediation is non-binding, meaning that taxpayers who pursue PAM are not required to reach an agreement with the IRS. However, when negotiating is the best option under the circumstances at hand, pursuing PAM can help facilitate a resolution that minimizes a taxpayer’s liability while also providing certainty for the future.
How Does the IRS’ New Pilot Program Change Post Appeals Mediation (PAM)?
The IRS’ new pilot program makes a single, but significant, change to the PAM process. As the IRS explains:
“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. . . . This change is . . . intended . . . 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.”
By assigning Appeals personnel who do not have any prior involvement with the taxpayer’s case, the pilot program seeks to ensure an unbiased approach to the negotiation process. Ultimately, the goal of the program is to help facilitate settlements in more cases, which will reduce the number of taxpayers who need to take the next step in the appeals process.
What if PAM Isn’t Desirable (or Isn’t Successful)?
If pursuing PAM isn’t desirable (or if the mediation process isn’t successful), challenging an unfavorable decision by the IRS’ Independent Office of Appeals typically involves going to federal court. Taxpayers can pursue appeals in federal court on various grounds, and, when necessary, litigating tax disputes with the IRS can help protect taxpayers’ financial interests long-term.
Schedule an Appointment with Washington D.C. Tax Attorney Kevin E. Thorn
Washington D.C. tax attorney Kevin E. Thorn, Managing Partner of Thorn Law Group, has extensive experience representing taxpayers before, during, and after the appeals process. If you have questions about filing an appeal, pursuing PAM, or litigating a tax dispute in court, call 202-349-4033 or contact us confidentially online to schedule an appointment today.
