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I guess this counts as introspection at the IRS (from the BNA Daily Tax Report)

PFA Program Requests Down Since $40,000 Application Fee Spike

The number of requests for the prefiling agreement program at examination level has dropped off significantly since 2007, says Lori Nichols, deputy director for prefiling and technical guidance in IRS’s Large and Mid-Size Business Division. “We’re not exactly sure what’s driving that,” she says. “We thought maybe that it would be a more popular program, particularly in light of certainty for tax issues,” she says. Since 2007, the application fee has jumped from $10,000 to $50,000, she notes