Internal Revenue Bulletin: 2005-23
June 6, 2005
Final regulations under section 330 of title 31 of the U.S. Code modify section 10.35 which prescribes specific requirements for covered opinions. Certain written advice issued after a tax return is filed, advice provided by taxpayer’s in-house counsel, and negative advice are excluded from the requirements of covered opinions. These regulations also clarify “principal purpose” and “prominently disclose”.
This procedure provides guidance on when an IRS examination is considered closed, when a closed examination may be reopened (to include reinspecting a taxpayer’s books of account), and who may approve a reopening. The procedure also describes by category certain IRS contacts with taxpayers and other actions taken as to taxpayers that are not examinations, inspections of books of account, or reopenings. Rev. Proc. 94-68 modified and superseded.
This document contains corrections to final regulations and removal of temporary regulations (T.D. 9198, 2005-18 I.R.B. 972) that relate to the recognition of gain on certain distributions of stock or securities of a controlled corporation in connection with an acquisition.
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