IRS Alters Section 469 Taxpayer Grouping Guidance, Includes Relief

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A new IRS revenue procedure requires taxpayers to report to the service their groupings and regroupings of activities and the addition of specific activities within their existing groupings for purposes of tax code Section 469. Rev. Proc. 2010-13 reflects comments submitted on Notice 2008-64 and contains a relief provision for taxpayers who can satisfy additional criteria to demonstrate their groupings of activities. IRS says it asked for public comment on Notice 2008-64's proposal for a disclosure regime for taxpayer groupings, specifically on whether the proposal sufficiently balanced the need for disclosure with taxpayer burden.