Larry Gibbs Discusses IRS Policy on Tax Accrual Work Papers in the BNA Daily Report for Executives

“Economic Substance Doctrine to Be Prominent Issue for IRS, Courts, Congress”
BNA Daily Report for Executives
01.19.10Former Commissioner of Internal Revenue Larry Gibbs said he has heard that IRS may soon issue a new policy of restraint with respect to seeking tax accrual work papers, a subject of intense interest in the practitioner community. Gibbs noted that senior IRS officials have said for more than a month that IRS is looking at this issue very closely and that there may be an announcement of some sort with regard to the policy. “Rumors abound and no one knows for sure—that I've been able to talk to outside the IRS—what's going to happen, or when it will happen, or if it will happen,” Gibbs said. “This is another initiative that I think bears watching into next year.” If the government obtains the work papers, Gibbs said, “It is a road map to where the soft spots are in the return by the company's own admission.”
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