IRS Will Not Initially Send Schedule UTP to Field Agents, Miller Says

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IRS will not initially send the forms taxpayers use to report their uncertain tax positions to field agents conducting exams, and will keep them in a specialized unit dedicated to their review, says IRS Deputy Commissioner for Services and Enforcement Miller. In a related development, the IRS official says he expects the agency to issue another set of FAQs and answers in the UTP area this summer, which will focus on such issues as the treatment of NOLs, recording a reserve, and acquisitions and dispositions. His comments at the 2011 OECD International Tax Conference come as taxpayers begin to include the Schedule UTP, Statement of Uncertain Tax Position, with returns for the 2010 tax year.

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