Key Takeaways
- The IRS has launched an IRS Post-Appeals Mediation (PAM) pilot program for certain unresolved Appeals cases.
- PAM allows a facilitated negotiation with a neutral mediator and a new Appeals team.
- Not every case qualifies, but the program shows there is still movement inside the IRS dispute process.
- Even after an appeal is denied, additional resolution paths may still exist.
Most IRS disputes don’t end when an appeal is denied. They end when you assume the process is finished.
That assumption makes sense. By the time your case (whether it be about an audit change you disagreed with or a penalty you disputed) reaches Appeals, you might feel you’ve reached the last real opportunity to explain your position. After that, things start to feel heavier. More formal. Harder to slow down.
From a procedural standpoint, though, an appeal denial usually means something much narrower. One stage has ended. The case itself often hasn’t.
That difference matters. And the IRS has recently acknowledged it with the introduction of the Post-Appeals Mediation (PAM) pilot program. PAM is aimed at disputes that have already gone through Appeals and have not been resolved. From a tax resolution standpoint, it confirms that an IRS “no” doesn’t necessarily mean the end of your options.
What is the Post-Appeals Mediation (PAM) pilot program all about?
The Post-Appeals Mediation (PAM) pilot program operates through the IRS Independent Office of Appeals. It’s available only for disputes that:
- Have already completed the Appeals process
- Remain unresolved
- Have not yet moved into Tax Court
Under PAM, both sides participate in a one-day mediation session with a neutral mediator. But the tone and structure are different from traditional Appeals.
A new Appeals team looks at the case. The goal is not to re-argue everything that’s already been said. It’s to identify where the case stalled and see whether it can move forward in a more focused setting.
In practical terms, PAM brings a neutral facilitator, a fresh set of eyes, and a framework designed to narrow issues quickly. When it works, it does so with far less cost and disruption than litigation. In some cases, it can make sense to bring in outside help from your trusted North Texas tax pro, as well (more on that below).
This is still a pilot program. Eligibility is limited, and both sides have to agree to participate.
Why this matters… even if PAM doesn’t apply to you
Most people don’t request Post-Appeals Mediation. Even so…
Why PAM matters is what it says about how these cases actually move with the IRS. If your appeal didn’t resolve, it doesn’t automatically mean the IRS rejected your position. Often, it means the case ran into limits inside the Appeals process, things like valuation issues, how arguments were framed, or what Appeals was allowed to concede.
PAM changes the structure of the conversation.
The mediator is still an IRS employee, but the pilot also allows you to bring in an outside co-mediator, at your own expense, if both sides agree.
In the right situation, involving a neutral party who wasn’t part of the original review (your Dallas County tax professional, for example) can make a real difference.
The bigger takeaway for you is this: IRS resolution happens in layers.
There are points where options narrow and others where they quietly reopen. Knowing where your case actually sits, and who needs to be involved at that stage, matters more than you might realize.
If the IRS denies your appeal, it doesn’t mean it’s a dead end
One of the more costly mistakes I see after people appeal IRS decisions is assuming a denial closes the file.
Most of the time, it doesn’t.
It usually closes one path. What comes next depends on timing, posture, and how the case was handled up to that point. That might include alternative resolution strategies, financial-based programs that weren’t viable earlier, or further negotiations. In some cases, it may involve litigation, but approached deliberately, not out of frustration.
Tax resolution rarely turns on who argues harder or sends more paper. It turns on understanding why a case stalled and what still has room to move.
PAM is simply one example of that reality showing up in policy.
What to do if your IRS appeal was denied
If your appeal was denied (or you’re still in Appeals and trying to think ahead), this is usually the point where uncertainty creeps in.
This is also where people who tried to appeal IRS actions often stop pushing. It’s not because there’s nothing left to do, but because the next step isn’t obvious.
Here’s where to focus.
1. Re-evaluate the case, not just the outcome. A denial doesn’t automatically mean the IRS rejected your position. Often, it reflects how the issue was framed, how documentation was presented, or limits within the Appeals process.
A second look can reveal where the case lost traction. In some situations, that’s exactly where newer programs like PAM come into play. One of PAM’s most meaningful features is that the case is reassigned to a new Appeals team, which makes it far easier to move a case forward with fresh eyes than to convince the same reviewer to reverse course.
2. Inventory all resolution paths. Appeals is one tool, not the entire system. Depending on the facts, that may include an Offer in Compromise, reconsideration, further negotiation, mediation, or other resolution strategies.
At the same time, timing matters. An Appeals denial letter often triggers a 90-day window to file a petition in U.S. Tax Court. If that deadline passes while you’re weighing options, you can permanently lose the right to judicial review even if other arguments might have been viable.
3. Get your documentation organized before urgency sets in. Whether the next step involves mediation, negotiation, or settlement, clarity creates leverage. Well-organized, well-supported records matter.
4. Work with someone who specializes in IRS dispute resolution. Tax resolution is a specialized discipline. Knowing the rules is important. Knowing how they’re applied — and where flexibility still exists — is critical. (This is a specialty for us, and one we’re happy to help you handle.)
Final thoughts
An IRS appeal denial often feels definitive. Procedurally, it usually isn’t.
The introduction of Post-Appeals Mediation doesn’t mean the IRS has softened its stance. It does suggest the agency recognizes that some disputes don’t resolve cleanly the first time.
If your appeal was denied — or you’re concerned it might be — a focused review can bring clarity about where things stand and what still makes sense to pursue.
If you need that type of expertise, that’s what we’re here for:
FAQs
“What are the most common reasons IRS appeals get denied?”
Often, appeal denials come down to documentation, valuation disagreements, or procedural limits within Appeals. A denial doesn’t always reflect the strength of the underlying position.
“How long does the IRS appeal process usually take?”
Timelines vary. Many Appeals cases take several months, and complex matters can take longer depending on workload and issue type.
“If I appeal IRS decisions and lose, do I still have options?”
In many cases, yes. A denial may close one path, but it doesn’t always end the case. Other resolution strategies may still be available depending on timing and posture.
“Can I hire a tax professional to handle my IRS appeal?”
Yes. Representation becomes especially important at the Appeals stage, where strategy and framing matter.
“Is an IRS appeal final, or can a case still move forward?”
An appeal can feel final, but procedurally, it often isn’t. Other resolution paths may still exist depending on timing and posture.
“How do I know what my next step should be after an appeal denial?”
That depends on why the appeal stalled and where the case sits procedurally. A focused review is usually the fastest way to get clarity.