80-361, confirming that a taxpayer need not recognize interest in circumstances for which there is doubtful collectibility
of such interest (the doubtful collectibility
While the dispute resolution process may not always provide the best opportunity for doubt as to liability compromises (although it can help to crystalize the issues for subsequent litigation), this forum can be a viable means for resolving assessments based on doubt as to collectibility
and penalty assessments based on reasonable cause.
An offer to compromise based on doubt as to collectibility
generally will be considered acceptable if it is unlikely that the tax can be collected in full and the offer reasonably reflects the amount the IRS could collect through other means, including administrative and judicial collection remedies.
NPOs need to (a) establish procedures that include a mechanism to reconcile donor-promised amounts to amounts recognized and (b) set up guidelines for periodic review of both the collectibility
of promises to give and the fair value of the underlying assets.
7122-1(b), an offer may be accepted if there is doubt as to liability or collectibility
, or if acceptance will promote effective tax administration.
In addition, it decreased days sales outstanding and increased collectibility
But Swiss watchmakers have re-established themselves at the high end of the market by relying on status, collectibility
and mechanical wizardry to attract buyers.
The agency can compromise with taxpayers on grounds of doubt either as to liability or collectibility
Due to a potential appeal by GTE/MR and issues relating to the collectibility
of the judgment, there is no assurance that the company will recover any amount from this verdict.
Factors that could affect future results include economic conditions in the Company's service areas, the effect of changes in the Company's mix of services on gross margin, the Company's ability to successfully integrate acquired businesses with its existing operations, future workers' compensation claims experience, the effect of changes in the workers' compensation regulatory environment in one or more of our primary markets, collectibility
of accounts receivable, and the use of net proceeds of approximately $33 million from the Company's 2005 follow-on equity offering, among others.
In addition to the traditional OIC standards of doubt as to liability or collectibility
, and as a result of the Internal Revenue Service Restructuring and Reform Act of 1998, the IRS is also required to take into account equity, hardship and public policy factors in promoting effective tax administration.
The IRS can compromise civil liabilities on grounds of either doubt as to the liability or doubt as to collectibility
10, 1993, alleges inadequacies in the company's public disclosures in filings with the SEC, press releases and other public statements, concerning the value of the company's assets, operations and financial condition, particularly concerning collectibility
of receivables, adequacy of reserves for losses, and the adequacy of the company's internal controls.
The IRS will compromise civil liabilities on grounds of either (1) doubt as to the liability or (2) doubt as to collectibility
Statement 114 also amends FASB Statement 5 on accounting for contingencies to clarify that a creditor should evaluate the collectibility
of both contractual interest and principal of all receivables when assessing the need to accrue a loss.