Welcome to the bimonthly publication IRS Insights, produced by Deloitte's
Tax Controversy Services Group to keep our clients abreast of current issues related to the Internal Revenue Service.
In this month's issue:
· IRS Updates Procedures for Reopening Closed Cases – On May 20, 2005, the IRS issued Rev. Proc. 2005-32, which updates procedures for reopening closed examinations under §7605(b) and describes when a case is deemed closed after examination. It also provides a nonexclusive list of contacts and actions by the IRS that are not considered examinations, inspections or reopenings of closed cases; explains when a closed case may be reopened to make an adjustment unfavorable to the taxpayer; and the approval process required to reopen a closed examination.
· LMSB Directive on Examination of Acquisition Transaction Costs – The IRS’s Large & Midsize Business Division has announced a directive providing examining agents with benchmarking tools to assist them in determining whether to audit the tax treatment of certain transaction costs arising from the acquisition (or disposition) of a trade or business in a merger or acquisition transaction under §1.263(a)-5(e)(3).
· Tax Controversy Update: IRS Releases Results on PFA Program – On May 31, 2005, the IRS, in Announcement 2005-42, released its annual report on the Pre-filing Agreement (PFA) program. The PFA program provides large and midsized corporate taxpayers with the opportunity to request IRS review of specific tax return issues prior to the filing of a tax return so that the issues are properly reflected on the tax return.
· Recent Guidance
See attached file for details.
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IRS Updates Procedures for Reopening Closed Cases
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Last Updated: April 12, 2006
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Source: Deloitte & Touche USA LLP - United States (English)
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