Error Correction PLRs

L1: Error Correction PLRsLast week, the IRS issued its 2nd error correction PLR. There were multiple issues resolved in this particular PLR; however, in the context of error correction; the IRS said:
“taxpayer represents that a mathematical error caused him to receive…less than the amount [properly] determined…[and] the error was not detected until January, 2005. Taxpayer proposes to receive a “make up” distribution in 2005 in the amount of the [error].”
“We [the IRS] conclude that the failure to distribute the entire required amount in 2003 and the subsequent “make up” distribution in 2005 will not be considered a modification… and therefore will not be subject to the 10% additional tax.”
As I mentioned above, this error correction PLR #2. It will become public in full sometime in January or February, 2006. Furthermore, I am aware of two other error correction PLRs that are under review within the AGC’s office as we speak; both of which I assess as having a good to high probability of being approved.
Clearly, the IRS is saying they will at listen and evaluate taxpayer facts, circumstances and intent.
TheBadger
wjstecker@wispertel.net
2005-10-26 17:58, By: TheBadger, IP: [66.250.23.21]

L2: Error Correction PLRsGreat information! This must be the new, friendlier IRS :~}2005-10-26 18:02, By: Gfw, IP: [172.16.1.71]

L2: Error Correction PLRsDo you know if the taxpayer submitted the PLR before or afterhe was caught by the IRS?
Mike2005-10-31 18:32, By: daddy0, IP: [69.120.56.189]

L2: Error Correction PLRsDo you know if the taxpayer submitted the PLR before or after he was caught by the IRS?
In the case of the PLR just issued — Before.
In the cases of the two pending —- one before one after.
We will see.
TheBadger
wjstecker@wispertel.net
2005-10-31 18:55, By: TheBadger, IP: [66.250.23.21]