Mark Allison Talks to Tax Notes on IRS Corporate Audit Campaigns
The IRS’s multiyear experiment with targeted Large Business and International Division compliance campaigns needs significant retooling, a Treasury watchdog says.
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But Mark Allison of Caplin & Drysdale said, “I think TIGTA’s assessment may not reflect the reality and difficulty of identifying issues that are appropriate for a campaign.”
Issues appropriate for LB&I’s campaign treatment are often revealed only after extensive evaluation of taxpayer reporting positions and selective audits, which provide the basis for a wider range of examinations and disclosures to determine which taxpayer positions are compliant or appropriate, Allison said.
“A campaign should not necessarily presuppose that an issue requires a determination of noncompliance, only that the issue requires further assessment because it poses a risk of noncompliance,” Allison said.
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- Senior Counsel