SECTION 9. NO PFA EXECUTED

.01 Post-filing procedures . If the Service and the taxpayer do not agree upon and execute a PFA that resolves an issue, either before or after the filing of the return to which the PFA relates, and the Service subsequently disagrees with the taxpayer’s treatment of the issue on the return, the taxpayer and the Service may continue their efforts to reach an agreement using post-filing procedures, such as the Accelerated Issue Resolution (AIR) procedures under Rev. Proc. 94–67, 1994–2 C.B. 800. This continuation of the process does not require a new application.

.02 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.