IRM Interim Guidance: Examining Returns Reporting Net Operating Losses (IRC §172)

Revision to Internal Revenue Manual 4.11.11, Net Operating Loss Cases, that would provide guidance to SB/SE and LB&I Examination operations on ensuring awareness of taxpayer’s actions with respect to carrybacks when examining tax returns reporting a net operating loss, released Feb. 10. To help ensure all actions taken by the taxpayer are considered during the examination, examiners should ask the taxpayer if the loss was carried back, and review IDRS at the beginning of the examination and again during the preparation of the proposed adjustments report for all eligible carryback years in search of category and/or transaction codes indicating ...