If not, amended returns
for the LLC and all of its members would be needed.
When effective: Notice 2004-54 applies to any original return, amended return
or extension request filed after 2003.
Under Method 2, a taxpayer would not include deductions or adjustments to E&P; these deductions or adjustments were to be included on an amended return
to be filed no later than the deadline for revoking the election (i.
446-1T(e)(2)(ii)(d)(3)(i): it either can file (1) an amended return
to correct the life; or (2) Form 3115, Application for Change in Accounting Method, to obtain automatic approval to switch to a different depreciable life, thus avoiding an amended return
Permit a taxpayer to file an amended return
and pay the tax and interest associated with an abusive tax shelter and avoid the assessment of a variety of penalties;
As computed by the Internal Revenue Service and the General Accounting Office, the "amount of tax due," however, clearly encompasses items that do not result from noncompliance, including (1) adjustments voluntarily made by taxpayers on qualified amended returns
Even if all of the prior years were within the SOL, X would have to file amended returns
for all of the affected years; each owner of X would also have to file an amended return
to recover the lost depreciation expense.
Further, it will not issue refunds on amended returns
claiming an interest deduction based on the case.
A provision of the President's 1993 Budget would amend section 6611(e) of the Internal Revenue Code to extend the 45-day grace period to all types of taxes and to amended returns
as well as claims for refunds.
6664-2(c)(4), the rules on qualified amended returns
may be modified by revenue procedure for "particular classes of taxpayers.
A letter to the IRS advising it that the taxpayer is in the process of preparing amended returns
or unfiled returns.
also should be filed by taxpayers who received educational assistance through their employers' qualified plans during the last six months of 1992.