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April 01, 2015
“It was in an example, but it wasn't crystal clear. If the IRS doesn't make a request under 6112, the information that’s provided won’t start the one-year statute running."
- Linda Z. Swartz, Chair of the Tax group at Cadwalader, commenting in Law360 on the clarification of certain conditions required to initiate the extended one-year assessment period for undisclosed listed transactions under Section 6501(c)(10), pursuant to recently released IRS regulations.