Administrative Appeals. If the Service and the taxpayer are unable to resolve an issue by a PFA or an AIR agreement, the taxpayer may pursue an administrative appeal either by requesting an early referral to Appeals under the procedures set forth in Rev. Proc. 99-28, 1999-2 C.B. 109, or by protesting any proposed deficiency related to the issue.
Appears in 6 contracts
Samples: Rev. Proc. 2005 12, Closing Agreement, Closing Agreement
Administrative Appeals. If the Service and the taxpayer are unable to resolve an issue by a PFA or an AIR agreement, the taxpayer may pursue an administrative appeal either by requesting an early referral to Appeals under the procedures set forth in Rev. Proc. 99-28, 1999-2 C.B. 29 I.R.B. 109, or by protesting any proposed deficiency related to the issue.
Appears in 3 contracts
Samples: Closing Agreement, Closing Agreement, Closing Agreement
Administrative Appeals. If the Service and the taxpayer are unable to resolve an issue by a an LMSB PFA or an AIR agreement, the taxpayer may pursue an administrative appeal either by requesting an early referral Early Referral to Appeals under the procedures set forth in Rev. Proc. 99-28, 1999-2 C.B. 29 I.R.B. 109, or by protesting any proposed deficiency related to the issue.
Appears in 1 contract
Samples: Closing Agreement