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Tax Lawyer, Vol. 55, No. 3 A GUIDE TO DEVELOPING A QUALITY PFA REQUEST 809 809 PARTICIPATION IN THE SERVICE’S PRE-FILING AGREEMENT PROGRAM: A GUIDE TO DEVELOPING A QUALITY PFA REQUEST David R. Stubblefield* I. INTRODUCTION With the issuance of Revenue Procedure 2001-22,1 the Service has expanded its issue-resolution process and offered the Pre-Filing Agreement Program (PFA) on a permanent basis to Large and Mid-Size Business (LMSB) taxpayers, a category that includes corporations, subchapter S...

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