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That the IRS needs time to process a refund claim or an amended return is wholly irrelevant to whether the taxpayer should be paid interest since the government has had the use of the taxpayer's money.
94-69's procedural requirements, it will be treated as a qualified amended return and generally will protect the taxpayer from the intentional disregard and substantial understatement components of the Sec.
filing an amended return after the extended due date
This would be true even if a taxpayer filed an original return in good faith, relying on the advice of competent tax advisers, but later filed amended returns after learning that the IRS considers a transaction in which the taxpayer participated to be an "abusive tax shelter.
Concededly, most large corporate taxpayers have the knowledge and wherewithal to reflect the ruling in their first post-December 7, 1990, return (or to absorb the cost and burden of preparing and filing an amended return in accordance with Announcement 90-144A (1)).
The tax litigation did not provide the taxpayers an extension to file amended returns.
TEI submits that the overriding purpose of section 446(e) must be kept in mind in constructing barriers to a taxpayer's filing amended returns to correct erroneous methods of accounting.
Until its response is known or additional cases are decided, taxpayers that want to make a MACRS class-life reclassification should consider protecting their positions by filing both a request for an accounting-method change and amended returns.
Frontier Chevrolet originally filed returns amortizing the covenant payments over 15 years, but filed amended returns claiming a five-year amortization period.
In 1999, NGS filed amended returns for its 1994-1996 tax years, stating that it was opting to elect out of MACRS, instead depreciating its rented gaming equipment using a method "not expressed in terms of years" under Sec.
For three consecutive years, a return preparer prepared amended returns that contained an understatement of liability due to willful or reckless conduct.