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Accounting firms, law firms, business groups, and professional associations sharply criticize IRS's proposal to require disclosure of uncertain tax positions—in many cases recommending withdrawal or suggesting other options. Stakeholders say that although they support IRS's intent to improve tax administration, the plan would create significant new burdens on taxpayers, could endanger relationships between taxpayers and their tax advisers, and threatens existing legal protections. Major targets for criticism include requirements that taxpayers provide IRS with a “maximum tax adjustment” for each position if not sustained in court and list rationales and reasons why positions are considered uncertain.
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