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IRS Expands Pre-Filing Agreement For Large Business

by Leroy Baker, Tax-News.com, New York

27 December 2004


Large and Mid-Size Business division taxpayers seeking to resolve certain tax issues prior to filing their tax returns may now do so for up to four years under the IRS Pre-Filing Agreement (PFA) Program.

The PFA program is designed to permit a taxpayer to resolve the treatment of an issue before the filing of a return.

According to the IRS, the program reduces taxpayer burden and makes more effective use of resources by eliminating tax controversy before the tax return is filed and providing certainty that agreed upon tax positions will not be challenged during the post-filing examination process.

“We have expanded the PFA program based on suggestions we received from taxpayers regarding how the IRS could improve the program,” explained Large and Mid-Size Business Commissioner Deborah M. Nolan.

“The changes reflect our focus on reducing taxpayer burden and, where possible, resolving issues during the pre-filing process,” he added.

Other issue resolution procedures, such as the Accelerated Issue Resolution (AIR) Program or Early Referral to Appeals, remain available to taxpayers who are not eligible for the PFA program or who are unable to reach an agreement through the PFA program.


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