Because Rev. Proc. 2001-22 limited the eligible years for the PFA program to current or prior taxable years for which returns were neither due nor filed, taxpayers and the Service could not resolve issues for multiple future taxable years or issues regarding appropriate methodologies for determining tax consequences that would affect future taxable years. The Service has determined that expanding the scope of the PFA program by allowing taxpayers and the Service to address certain issues over a limited number of future taxable years will significantly benefit both taxpayers and the Service.
