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November 17, 2022

IRS provides special procedures allowing eligible taxpayers to file qualified amended returns and prevent imposition of accuracy-related penalties

The IRS has issued guidance (Revenue Procedure 2022-39) prescribing special procedures under which eligible taxpayers may: (1) file qualified amended returns in accordance with Treas. Reg. Section 1.6664-2(c)(4)(ii); and (2) show additional tax due or adequately disclose an item or position on a previously filed return to prevent the IRS from imposing accuracy-related penalties. The new guidance obsoletes Revenue Procedure 96-69; for background, see Tax Alert 2020-2130. A Tax Alert is forthcoming.