Information provided in response to a question or request from Appeals to clarify or corroborate information identified in the revenue agent's report
, the protest, or the rebuttal to the protest generally can be considered by Appeals without sending it to Examination for review.
Consequently, at the outset of an examination both sides should agree, for example, on the likely date for conclusion of the examination and issuance of the revenue agent's report
The Joint Committee on Taxation affirmed the IRS Revenue Agent's report
concluding that the Company (1) does not owe any additional taxes for those periods, (2) is entitled to receive an additional refund of $1.
However, examiners have to pursue issues on the capitalization of 12-month expenses for ongoing examinations in which capitalization of the expenditures resulted in their preparing Form 5701, Notice of Proposed Adjustments, or Form 4549, Revenue Agent's Report
We believe that the reports of specialists should be timely received by the Case Manager and should not delay the timely issuance of the Revenue Agent's Report
Disclosure to taxpayer of third-party tax information: P's exam team sought to disclose the information it obtained to P in its Revenue Agent's Report
In addition, even where the pertinent revenue agent's report
does not address the taxpayer's transfer pricing methodology, reliance on results of a prior audit should be a factor in establishing whether a taxpayer has reasonable cause for its methodology.
13, 1988, the date of the referral to CID) to when the civil aspects resumed (April 15, 1994, the date the revenue agent's report
was sent to T).
482 at trial was not a new matter; although the section was not mentioned in the deficiency notice, it was cited and relied on in the revenue agent's report
the ommission of material facts), a taxpayer has substantial authority for the tax treatment of an item if such treatment is supported by a ruling or determination letter issued directly to the taxpayer, a technical advice memorandum in which the taxpayer is named, or an affirmative statement in a revenue agent's report
for a prior taxable year of the taxpayer.