PFTGPre-Filing and Technical Guidance (Large and Mid-Size Busines Division; US IRS)
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PFTG management has indicated that LMSB does not wish to create the same patina for the audit of a tiered issue as there was in audits of listed transactions, even though listed transactions are included as one of the Tier I issues.
PFTG management has indicated that the Issue Focus approach is not intended to eliminate discretion by the regular examination teams.
Although PFTG disclaims any desire to create "cookie-cutter" resolutions or "one-size-fits-all" packages, it places great importance upon consistency for similarly situated taxpayers.
PFTG has indicated that the standardized IDRs should not be viewed as set in stone, but rather (like the situation with all other IDRs) the examiners should be willing to discuss reasonable changes that make sense under the particular circumstances.