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The frustrating state business purpose audit.
Overview
I am probably not alone in my frustration with many of the audit techniques being employed by state auditors. Now don't get me wrong, I am all for a state enforcing its laws and assuring that taxpayers are in compliance therewith. My frustration stems from what appears to be a departure from fact-finding and utilization of objective audit tools the states have at their disposal (e.g., conformity to Internal Revenue Code ["the Code"] Sec. 482-type provisions, etc.). It seems all too frequent those auditors have abandoned these tools and, instead, have focused on attempting to disallow transactions or corporate restructurings based on their belief that the ...
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