Tax litigation computations are comprehensive. They bring the original return line item figures forward through the IRS field examination proposed but unagreed adjustments, the Statutory Notice of Deficiency computations, and the proposed adjustments incident to the Tax Court litigation. They also include the estate’s counterproposals. A final series of computations usually incorporates the settlement figures to gauge the future consequences to the estate including any “catch-up” payment due as part of a continuing 6166 deferral.
The computations include a summary of all IRS account activity showing assessments, abatements, payments, allocations of payments between tax and interest, and required adjustments to specific IRS account categories to adjust the existing assessments to match the new figures in the computations.
The same is true for litigation cases in U.S. District Court. In any event, tight deadlines are normal with these computations.
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