Common use of Accelerated issue resolution Clause in Contracts

Accelerated issue resolution. If the Service and the taxpayer do not agree upon and execute a PFA that resolves an issue, either before or after the filing of the return to which the PFA relates, and the Service subsequently disagrees with the taxpayer's treatment of the issue on the return, the taxpayer and the Service may continue their efforts to reach an agreement using post-filing procedures, such as the Accelerated Issue Resolution (AIR) procedures under Rev. Proc. 94-67, 1994-2 C.B. 800. This continuation of the process does not require a new application.

Accelerated issue resolution. If the Service and the taxpayer do not agree upon and execute a PFA that resolves an issue, either before or after the filing of the return re- turn to which the PFA relates, and the Service Ser- vice subsequently disagrees with the taxpayer's tax- payer’s treatment of the issue on the return, the taxpayer and the Service may continue their efforts to reach an agreement using post-filing procedures, such as the Accelerated Accel- erated Issue Resolution (AIR) procedures under Rev. Proc. 94-6794–67, 1994-2 1994–2 C.B. 800. This continuation of the process does not require a new application.