Post-filing procedures. 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 tax return to which the PFA relates, and the Service subsequently disagrees with the taxpayer's treatment of the issue on the tax 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. This continuation of the process does not require a new application.
Appears in 3 contracts
Samples: Closing Agreement, Closing Agreement, Closing Agreement
Post-filing procedures. 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 tax return to which the PFA relates, and the Service subsequently disagrees with the taxpayer's treatment of the issue on the tax 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.
Appears in 2 contracts
Samples: Closing Agreement, Closing Agreement
