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At a recent Tax Executives Institute conference in New York, an Internal Revenue Service (IRS) spokesperson said guidelines and a new final form will be released when the IRS and the State Treasury Department United States will supersede the disclosure procedures set forth in Tax Procedure 94.-69 1994-2 CB 804. The updated guidelines will define the scope of information required and detail how to create it.
As we discussed earlier, the IRS released a new draft form (Form 15307, Post-Filing Disclosure for Specified Taxpayers for Large Businesses) in February 2022 and asked for feedback on the new form. A significant amount of helpful feedback has been received from taxpayers and tax professionals on Form 15307 and the IRS is in the process of finalizing the form based on this feedback, which will be released to assist with implementation. new guidelines replacing tax procedure 94-69. No timeline was provided on when the new form and guidelines will be released.
Practical point: We’re glad to hear that the 94-69 tax litigation disclosure procedures are here to stay, albeit in one form or another. Many large corporate taxpayers rely on this mechanism to correct errors made on the return without having to file an official amended return.
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