Friday, May 18, 2012
Ned Hillenbrand (J.D. 2012, Washington & Lee), Note, United States v. Textron: The Right Answer to a Billion-Dollar Question, 68 Wash. & Lee L. Rev. 1973 (2011):
This Note discusses the use of a public corporation’s tax accrual workpapers to (1) shrink the IRS-taxpayer disclosure gap and (2) hold those corporations accountable for knowingly taking unsustainable positions on their tax returns. Further, this Note addresses criticisms and concerns regarding the use of these materials as a resource during an IRS audit investigation.