Tax Analysts publishes news, analysis, and commentary on tax issues regarding settlements and tax dispute resolution, including settlements with the IRS, taxation of settlement payments, settlement payment deductions, designated or qualified settlement funds, and fast track settlement programs.

Section 6159 allows the IRS to enter into written agreements with taxpayers allowing the payment of tax in installments. Section 7121 allows the IRS to enter into closing agreements with taxpayers. Section 7122 allows the IRS to compromise on any civil or criminal case under the tax code. Section 7123 provides the appeals dispute resolution procedures under which either the taxpayer or the IRS Appeals office may request non-binding mediation for any issue still open after appeals or after failed attempts to produce a closing agreement or compromise.

IRS Publication 4345 provides guidance on the tax treatment of payments that an individual receives from the settlement of a lawsuit. Whether settlement proceeds must be included in income depends on all the facts and circumstances in a given case. Tax Analysts publishes numerous IRS and court documents, along with analysis, on the taxation of various settlement payments. A taxpayer's payment of liabilities incurred to settle a lawsuit may also be deductible as ordinary and necessary business expenses under section 162 (LTR 201412002).

Section 468B provides special rules for designated or qualified settlement funds. Tax Analysts publishes documents and analysis addressing tax issues and consequences involving the funds. (ILM 201450019; "Qualified Settlement Funds in Corporate Transactions.")

News stories and IRS documents published by Tax Analysts cover the IRS’s fast-track settlement program, which uses alternative tax dispute resolution techniques to help taxpayers save time and avoid a formal administrative appeal or lengthy litigation. Tax Analysts also publishes IRS tax settlement guidelines, which outline the IRS's position on settling specific tax issues, including abusive tax avoidance transactions, intangibles, real estate, insurance, partnerships, mergers and acquisitions.