Common use of Administrative Appeals Clause in Contracts

Administrative Appeals. If the Service and the taxpayer are unable to resolve an issue by a PFA or an AIR agreement, the taxpayer may pursue an administrative appeal either by requesting an early referral to Appeals under the procedures set forth in Rev. Proc. 99-28, 1999-2 C.B. 109, or by protesting any proposed deficiency related to the issue.

Administrative Appeals. If the Service and the taxpayer are unable to resolve an issue by a PFA or an AIR agreement, the taxpayer may pursue an administrative appeal either by requesting an early referral to Appeals under the procedures set forth in Rev. Proc. 99-28, 1999-2 C.B. 29 I.R.B. 109, or by protesting any proposed deficiency related to the issue.

Administrative Appeals. If the Service and the taxpayer are unable to resolve an issue by a an LMSB PFA or an AIR agreement, the taxpayer may pursue an administrative appeal either by requesting an early referral Early Referral to Appeals under the procedures set forth in Rev. Proc. 99-28, 1999-2 C.B. 29 I.R.B. 109, or by protesting any proposed deficiency related to the issue.