SECTION 11. DISCLOSURE

PFAs are agreements described in section 6103(b)(2)(D). A PFA and the information generated or received by the Service during the PFA process constitute confidential return information. Consistent with the restrictions of section 6103, the Service will continue to publish annual reports summarizing the operation of the PFA program. PFAs are not written determinations available for public inspection under section 6110. PFAs are exempt from

January 21, 2009 331 2009–3 I.R.B.