IRS Devising Guidance on UTP Reporting, Focusing on Reserves, NOLs

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IRS is working on more guidance for taxpayers to use in reporting their uncertain tax positions to the government, with a focus on what it means to record a reserve and the treatment of net operating losses, IRS officials say. The update comes as taxpayers already are beginning to submit the first round of Schedules UTP, Statement of Uncertain Tax Position, due for tax year 2010 for the nation's largest taxpayers. Questions continue to surround the process despite several iterations of guidance.