IRS Releases Schedule UTP Filing Statistics From 2011 Tax Year

1,783 taxpayers filed Schedule UTP for TY2011. (This compares to 1,761 taxpayers at the same time last year. Total returns filed and number of issues disclosed will increase as late year filters and other returns are filed)

83% of all returns filed with Schedule UTP were filed by IC taxpayers.

4,120 tax positions have been disclosed on Schedule UTPs for TY 2011.

Returns filed by CIC taxpayers with a Schedule UTP averaged 3.8 uncertain tax positions per Schedule, while returns filed by IC taxpayers with a Schedule UTP averaged 2.0 positions per Schedule.

• Note that beginning with TY2011, corporations are required to report tax positions taken in the prior year on Part II of Schedule UTP if that position was not reported on the prior year Schedule. As such, we expect a slight increase in the average number of total positions reported per taxpayer. We will at a later date begin to break out the total number of positions reported between current year and prior year positions.

47% of all Schedule UTP returns filed included only one uncertain tax position.

IRS is still compiling the data regarding the top code sections reported with the TY2011 filings, although we do not expect much variation from TY2010. That information will be posted as soon as it becomes available.