Westview Gerontology filed their return that is under audit on March 11, 2020. The audit has been dragging on and the outside accountants for the corporation have been unable to come to agreement with the auditor, Wanda Wild. It is now September 2022 and the statute of limitations is nearing its expiration. The IRS would like Westview to sign a Form 872-A.

As the outside accountant for Westview, you are to write a memo to the taxpayer explaining the difference between a Form 872 and a Form 872-A, along with a recommendation as to which they should agree to sign and why. What would happen if they refuse to sign either form? Research your response and use proper tax citation in your memo.