Common use of Criteria for Selection Clause in Contracts

Criteria for Selection. The criteria for selecting taxpayers to participate in the PFA program include, but are not limited to: (1) Whether the specific issue presented by the taxpayer’s facts is an eligible issue under section 3 of this revenue procedure and is otherwise suitable for the PFA program; (2) The direct or indirect impact of a PFA upon other years, issues, taxpayers, or related cases; (3) Whether Service resources are available; (4) Whether the taxpayer is willing and able to dedicate sufficient resources to the PFA process; (5) Whether the PFA is likely to result in two or more persons taking contrary positions on an item or transaction (a “whipsaw” issue); (6) The time remaining until the due date and expected filing date, if earlier than the due date, of the earliest return to which the PFA relates; and (7) The overall probability of completing the process and entering into a PFA by the proposed date for filing the earliest return to which the PFA relates. Early submission of a request will facilitate completion of a PFA before any associated returns become due. As a result, early requests are more likely to be selected for the PFA program and the Service urges taxpayers to submit PFA requests as early as possible.

Criteria for Selection. The criteria for selecting taxpayers to participate in the PFA program include, but are not limited to: (1) Whether the specific issue presented by the taxpayer’s 's facts is an eligible issue under section 3 of this revenue procedure and is otherwise suitable for the PFA program; (2) The direct or indirect impact of a PFA upon other years, issues, taxpayers, or related cases; (3) Whether Service resources are available; (4) Whether the taxpayer is willing and able to dedicate sufficient resources to the PFA process; (5) Whether the PFA is likely to result in two or more persons taking contrary positions on an item or transaction (a “whipsaw” issue); (6) The time remaining until the due date and expected filing date, if earlier than the due date, of the earliest return to which the PFA relates; and (7) The overall probability of completing the process and entering into a PFA by the proposed date for filing the earliest return to which the PFA relates. Early submission of a request will facilitate completion of a PFA before any associated tax returns become due. As a result, early requests are more likely to be selected for the PFA program and the Service urges taxpayers to submit PFA requests as early as possible.

Criteria for Selection. The criteria for selecting taxpayers to participate in the PFA program include, but are not limited to: (1) Whether the specific issue presented by the taxpayer’s 's facts is an eligible issue under section 3 of this revenue procedure and is otherwise suitable for the PFA program; (2) The direct or indirect impact of a PFA upon other years, issues, taxpayers, or related cases; (3) Whether Service resources are available; (4) Whether the taxpayer is willing and able to dedicate sufficient resources to the PFA process; (5) Whether the PFA is likely to result in two or more persons taking contrary positions on an item or transaction (a “whipsaw” issue); (6) The time remaining until the due date and expected filing date, if earlier than the due date, of the earliest return to which the PFA relates; and (7) The overall probability of completing the process and entering into a PFA by the proposed date for filing the earliest return to which the PFA relates. Early submission of a request will facilitate completion of a PFA before any associated returns become due. As a result, early requests are more likely to be selected for the PFA program and the Service urges taxpayers to submit PFA requests as early as possible.

Criteria for Selection. The criteria for selecting taxpayers to participate in the PFA program include, but are not limited to: (1) Whether the specific issue presented by the taxpayer’s facts is an eligible issue under section 3 of this revenue procedure and is otherwise suitable for the PFA programpro- gram; (2) The direct or indirect impact of a PFA upon other years, issues, taxpayers, or related cases; (3) Whether Service resources are available; (4) Whether the taxpayer is willing and able to dedicate sufficient resources to the PFA process; (5) Whether the PFA is likely to result in two or more persons taking contrary positions po- sitions on an item or transaction (a “whipsawwhip- saw” issue); (6) The time remaining until the due date and expected filing date, if earlier than the due date, of the earliest return to which the PFA relates; and (7) The overall probability of completing complet- ing the process and entering into a PFA by the proposed date for filing the earliest return re- turn to which the PFA relates. Early submission of a request will facilitate fa- cilitate completion of a PFA before any associated returns become due. As a resultre- xxxx, early requests are more likely to be selected se- lected for the PFA program and the Service urges taxpayers to submit PFA requests as early as possible.