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IRC § 42 Audit Technique Guide

IRC § 42 Audit Technique Guide. Draft ATG has been completed and reviewed by Chief Counsel 20 Chapters & 10 Appendices Adobe file is 312 pages 132,990 words Draft ATG cannot be cited as authority for ANY reason. Process Draft released for public comment in Dec.

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IRC § 42 Audit Technique Guide

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  1. IRC §42 Audit Technique Guide • Draft ATG has been completed and reviewed by Chief Counsel • 20 Chapters & 10 Appendices • Adobe file is 312 pages • 132,990 words • Draft ATG cannot be cited as authority for ANY reason

  2. Process • Draft released for public comment in Dec. • Internal review by interested parties • Comments due March 28, 2014 • Comments submitted to Grace Robertson and will be shared with Chief Counsel • Revisions made based on comments • Post to IRS website (html & Adobe pdf)

  3. Highlights • Organized for examiners auditing taxpayers owning IRC §42 projects (usually partnerships) • Content complements Form 8823 Guide, does not replace it. • Process (beginning to end) • Issue Development Depth (high to low level) • Chapter 12, Applicable Fraction (46 pages) includes cross references. • Chapter 15, Computing Adjustments to the Allowable Annual Credit

  4. In-depth discussion of Eligible Basis (Chapters 8-11 and Appendix C) • Developer Fees (pages 8-15 to 8-25) • Nonprofit Set-Aside (Chapter 6) explains tax consequences of noncompliance • Relevant court cases (Appendices F-J) • Glossary of Terms (Appendix A) • References with full citation (Appendix B) • Documentation requirements • Audit techniques

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