February 11, 2000
IRS Pilots Pre-Filing Agreement Program
for Large Businesses
WASHINGTON - Under a new program announced today, large business taxpayers
may request a pre-filing agreement with the Internal Revenue Service to resolve
specific issues relating to tax returns they will file later this year. Using the pilot
pre-filing agreement procedure, both taxpayers and the IRS can in a cooperative
environment resolve issues likely to be disputed in post-filing examinations.
Notice 2000-12 describes the pilot program.
Pre-filing agreements are a significant way the IRS and business taxpayers can
work together to resolve issues up front. We can work to resolve potential
issues before the return is filed and minimize the controversy during an
examination, said Larry R. Langdon, Commissioner of the Large and Mid-Size
Business Division of the IRS. This approach will result in interaction that is
less time consuming, expensive and contentious. That benefits both the taxpayer
and the IRS.
The pre-filing agreement (PFA) program pilot, scheduled to begin in March, will
cover issues on returns that will be filed between September-December 2000.
Some examples of issues that might be resolved in the PFA program include
valuation of assets and the allocation of purchase or sales price among assets
acquired or sold; in-house research expenses, and valuation of inventories.
Notice 2000-12 provides examples of issues likely to be suitable for resolution
through the pilot PFA program.
The pre-filing agreement pilot
program is open to large businesses that currently have a Coordinated
Examination Team on site. Businesses interested in participating in the pilot
program should contact their on site Case Manager as soon as possible. Requests
to participate in the pilot should be submitted by March 15, 2000. Additional
information on the PFA pilot may be found in Notice 2000-12 on the IRS Web site
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