Examples of Accelerated Issue in a sentence
A written statement furnished by a taxpayer subject to the Coordinated Examination Program or a written statement furnished by the taxpayer when electing Accelerated Issue Reso- lution or similar procedures will be considered an amended return for pur- poses of this section if it satisfies ei- ther the requirements of a qualified amended return for purposes of § 1.6664– 2(c)(3) or such requirements as the Commissioner may prescribe by rev- enue procedure.
A taxpayer not selected for the PFA program remains eligible for other early issue resolution procedures, including the Accelerated Issue Resolution (AIR) program (see Rev.
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.
A taxpayer not selected for the PFA program remains eligible for other early issue resolution procedures, including the Accelerated Issue Resolution (AIR) program.
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.
The conversion shall be deemed to have been effected immediately prior to the close of business on the Accelerated Issue Date and the Common Shares issuable upon conversion shall be deemed to be issued as fully paid and non-assessable at such time.
In 1994, the IRS established the Accelerated Issue Resolution (“AIR”) program in Revenue Procedure 94-67.
Within ten (10) Business Days after the Accelerated Issue Date, provided a certificate or direct registration statement for the required number of Common Shares has been issued to the Holder, an upon payment of all accrued and outstanding interest due pursuant to this Note, this Note shall be cancelled.
A taxpayer not selected for the PFA program remains eligible for other procedures for early issue resolution, including the Accelerated Issue Resolution (AIR) program (see Rev.
Several other innovative procedures — such as Limited Issue Focused Examination (LIFE), Pre-Filing Agreements, Fast Track Mediation and Settlement, Accelerated Issue Resolution, Advance Pricing Agreements, and Early Referral to Appeals — have also sou ght to improve the examination process and promote currency.