Intent to Litigate Example Included in 2011 Schedule UTP Instructions

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Companies will have to report uncertain tax positions in some cases where they have not recorded a reserve because they intend to litigate an issue, IRS says in a new example in the instructions to the 2011 Schedule UTP. The new form and instructions, posted on IRS's website, offer more guidance on reporting reserves, including another new example on reporting reserves in subsequent years. The development is the latest in IRS's implementation of a requirement that companies report their uncertain tax positions to the government.