under examination

References in classic literature ?
The second, to divide each of the difficulties under examination into as many parts as possible, and as might be necessary for its adequate solution.
93-60, in anticipation of forthcoming guidance, and provided that it would: (1) not accept any voluntary requests for accounting-method changes for loan origination costs; and (2) treat taxpayers faced with tiffs issue on examination no less favorably titan those not under examination for these costs, if such taxpayers made a protective filing under Arm.
A taxpayer under examination (or a power of attorney) contacts the IRS team manager handling the audit with a PFA request.
05, the examining agent "will effect the change in the earliest taxable year under examination.
The agent is instructed to make the change in the earliest tax year under examination, with a one-year Sec.
Although this definition and condition for availability of VCR or Walk-in CAP may be defensible in respect of smaller employers and their plans, which are only infrequently or occasionally examined by the IRS, it is neither workable nor equitable when applied to large employers in the Coordinated Examination Program (CEP) or similar employers (such as "district-level" CEP taxpayers) whose income tax returns are essentially always under examination or that have received "notice" of a pending examination.
A taxpayer under examination before Appeals or before any Federal court is permitted to change its accounting method for shrinkage to the methods provided in the revenue procedure; however, such a taxpayer would not receive audit protection for prior years if shrinkage is an issue under consideration on the date of filing the Form 3115.
01(1) states the general rule that a taxpayer under examination may not request a change in accounting method unless it qualifies under either the 90- or 120-day windows of sections 6.
However, if the taxpayer is already under examination by the Service, this request will generally be rejected.
That expands the opportunity for a revenue agent to take an agreement that has been arrived at in the Appeals function and move it out of Appeals into the year that is currently under examination.
92-20, including modifications of general filing requirements, window periods, rulers for taxpayers under examination, and terms and conditions -- most important, the elimination of the Category A and B distinction and the provision of a uniform four-year section 481(a) adjustment.
Taxpayers under examination who wish to consider a CSP-type settlement should be aware of this time frame.