Three recent Federal Court cases, Premier Tech v. United States, No. 2:20-cv-890-TS-CMR (D. Utah 2021); Intermountain Electronics v. United States, No. 2:20-cv-00501-JNP (D. Utah 2021); and Harper v. United States, 847 F. Appx. 408 (9th Cir. 2021), remind taxpayers of the “specificity” requirements in making Claims for Refund. While we will not delve into each case here, the practice point to remember is that taxpayers are well-served to provide a wealth of detailed information to the IRS as part of the claims process, to provide the IRS with enough information to adequately consider whether to grant the refund request, and to carefully state the basis for the refund claim. Doing so should be enough to overcome a lack of “specificity” challenge by the IRS.
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