Patricia Sweeney discusses the proposed IRS rule requiring companies with more than $10 million in total assets to disclose uncertain tax positions on the new Schedule UTP, Uncertain Tax Position Statement. Some groups have urged the IRS to withdraw the proposal. "It’s extraordinarily unlikely that the IRS will pull back and withdraw," said Sweeney. "At best it may be deferred, or limited to certain groups of taxpayers. We’re talking about tinkering around the edges and not getting rid of it altogether. But there is a strong case to defer implementation for a year to give the IRS time to train and put systems in place," she said. "They need to know what they are going to do with this information. And more important, they need to train and provide additional resources for the examination process. Otherwise there will be very inconsistent treatment of taxpayers."