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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.

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Presentation on theme: "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."— Presentation transcript:

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 ANYDraft 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. 1.Process (beginning to end) 2.Issue Development Depth (high to low level) 1.Chapter 12, Applicable Fraction (46 pages) includes cross references. 2.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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