A systematic approach to tax controversy management.
Tax Executive › Vol. 49 Nbr. 3, May 1997
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Summary
Corporate tax managers can use a structured approach to assess tax controversies and form proper strategies to either settle or contest such controversies. An infuence diagram and decision tree provide a logical, cost-effective, and systemic risk assessment framework for understanding the tax issues involved and deciding the chances of success in litigation. Timing is important in assessing litigation risks and may be a necessary component of tax planning.
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A systematic approach to tax controversy management.
The past ten years have brought two significant changes in the nature of the federal tax controversies. Historically, virtually all federal tax controversies were settled. Most are still settled today. Today, however, many taxpayers find settlement virtually impossible short of total surrender. The second change is the increased factual focus of tax controversies. A critical element, if not the critical element, for a large number of disputes is what are the facts. Section 482 pricing...
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