Status 12 says an IRS examination started. It does not prove the ERC issues were developed. Letter 105-C cases can reach Appeals—and PAM—with a remarkably thin file.

ERC and research credit disputes are fact-heavy, document-heavy, and often difficult to resolve through position papers alone. PAM can create the focused conversation these cases need.

The useful question is not whether IRS ADR exists. It is which procedure is available in the case’s present posture—and what may be lost if it fails.

One of the most effective — and often underutilized — tools in federal tax controversy is the IRS Post Appeals Mediation (PAM) Program. While tax disputes can sometimes feel like they are headed toward an unavoidable collision course, PAM offers taxpayers and the IRS an opportunity to step into a structured, solution-oriented environment focused on resolution rather than escalation.

Heath Vo, JD, CPA, Founding Principal, ExFed Tax IRS Alternative Dispute Resolution (ADR) programs offer taxpayers a faster, less adversarial way to resolve tax disputes without going to court. Managed by the IRS Independent Office of Appeals, these programs use mediation and settlement strategies to help taxpayers and the IRS reach fair, mutually agreeable outcomes. Why Consider ADR for IRS Tax Disputes? If you’re under IRS examination or facing unresolved tax issues conside