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Uncertain tax positions document requests and audit guidelines

IRS is expanding its policy of restraint in connection with the requirement that certain corporations must file Schedule UTP, Uncertain Tax Position Statement. IRS has announced that it will forgo seeking particular documents that relate to uncertain tax positions and the work papers that document the completion of Schedule UTP. These new policies will be incorporated into Internal Revenue Manual (IRM) 4.10.20. In addition, a new Large Business and International Division (LB&I) Directive reflects IRS intentions to go lightly on UTP audits.

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