Experienced Tax
Accountant –
The IRS issued an administrative summons to Titan, a manufacturing company, to
inspect its 2009 books for an audit of its 2010 tax return. Titan refused to
comply, arguing that because the IRS had previously audited TitanÆs 2009 tax
return and hadnÆt issued a notice, the Section 7605(b) rule prohibited the IRS
from obtaining the 2009 documents a second time. [Under IRC Sec. 7605(b), only one
inspection of a taxpayerÆs books and records can be made for each tax year
unless the Treasury Secretary notifies the taxpayer that an additional
inspection is necessary.] The Seventh Circuit affirmed the district courtÆs
decision ordering Titan to comply with the summons, concluding that the one
examination per tax year rule doesnÆt apply if the second exam is for a
different tax year.
If
you've received an audit notice from the IRS, for no obligation free
consultation contact us today!
Amare
Berhie, Senior Tax Accountant
(651)
300-4777, (612)424-1540, (651) 621-5777
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