Section 4.4 Open Tax Years/Existing IRS Audit

JurisdictionUnited States

4.4 Open Tax Years/Existing IRS Audit

The IRS may be in the midst of an income tax audit or may file a substantial tax claim. The parties must determine whether there is substantial tax exposure and develop contingency plans for such a tax dispute. Failure to anticipate such circumstances can cause serious delays in plan confirmation. If there are substantial taxes to be paid for the year of the planned filing (for example, because of...

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