The irony of the Supreme Court's decision not to review this case is that it probably doesn't materially change a corporate taxpayer's position. Why? Because the transparency the IRS sought by requesting Textron's workpapers, and by litigating this case to the highest level, has already been provided for in other forms-most notably, the recently proposed schedule of uncertain tax positions.
Accounting & Auditing Textron Ruling Leaves Tax Compliance Confused By Tammy Whitehouse find some legal privilege or pro
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