John L. Abramic


Since the inception of the IRS Advance Pricing Agreement ("APA") program in 1991, the IRS, in order to protect participant confidentiality, had refused to disclose APAs. In 1996, The Bureau of National Affairs filed suit against the IRS in order to force disclosure of APAs. Before the dispute was resolved in 1999, Congress amended section 6103 of the tax code to include APAs among the types of confidential tax return information that may not be publicly disclosed. This Note discusses the law relevant to the issue of whether or not APAs should be disclosed, the recent litigation concerning APA disclosure, the more recent legislation concerning APA confidentiality, and the tension between public agency review and taxpayer confidentiality.

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