Deloitte
Accounting Research Tool
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Chapter 4 — Uncertainty in Income Taxes

4.6 Other Topics

4.6 Other Topics

Footnotes

2
Presenting affirmative adjustments upon examination, rather than claiming the position on an originally filed income tax return, might be part of the entity’s strategy to avoid penalties on a particular tax position in a particular tax jurisdiction or to limit the jurisdiction’s ability to make other changes to the year (i.e., changes that are unrelated to the adjustment being sought by the entity).
3
Some states require an entity to be accepted into the voluntary disclosure program before being afforded audit protection for previous years.