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Rev proc 85-15 Form: What You Should Know
THE ADDRESS. The revenue procedure for implementing AAP's provides the procedures for amending annual return statements filed with the Revenue Office (as well as other IRS forms), to achieve additional AAP's in the event of events including but not excluding, but not limited to, major corporate reorganizations, substantial changes in accounting period, reorganizations of the group with separate financial statements of the combined groups or changes in internal controls which would have affected a previous statement. REVIEW OF REVERSE ANALYSIS. When an applicant has a reason to believe that a previous statement was incorrect, the applicant should obtain a reversal of the incorrect statement from the IRS. If the applicant receives an incorrect statement it generally means that the applicant is entitled to recover the costs of updating the statement under the reverse audit doctrine. PURPOSE OF REVERSE ANALYSIS. The following is a summary of the purpose of reverse audit analysis (RAM): (i) to enable a taxpayer to challenge a statement made at the request of another taxpayer; (ii) to assist in assessing penalties and interest under Sec. 162; and (iii) to obtain evidence of other tax law violations. A taxpayer who believes that a statement made at the request of another taxpayer is incorrect should obtain a reversal of the incorrect statement from the other taxpayer for the purpose of establishing that the original statement was correct. In this section, reversal of the improper statement is also referred to as reverse audit. The taxpayer should also obtain the other taxpayer's consent to reverse the improper statement. For the purposes of Rev. Pro. 83-9, 1983-1 C.B. 623 (“Rev. Pro. 83-9"), the improper statement is a statement made in the return or return supplement which is incorrect in principle or application or which is based on an erroneous interpretation of regulations, or is not in substantial compliance with the regulations. PURPOSE OF REVERSE ANALYSIS. (A) The purpose of a reversal audit is to obtain evidence of other tax law violations if the improper statement was based on errors in the method or method of supply or distribution. (B) Under Rev. Pro.
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