8/24/2010

The Internal Revenue Service has issued final regulations allowing it to reduce businesses' tentative refunds by the amount of certain unassessed tax liabilities, if those liabilities have been identified in a notice of deficiency or bankruptcy proof of claim. The final regulations adopt an expansive definition of taxes "then due" put forth in temporary regulations in 2007 and abandon the earlier, taxpayer-friendly position of Rev. Rul. 78-369.

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