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Contract analysis / letter-to-irs-protest-extension-20231115.docx
letter-to-irs-protest-extension-20231115.docx
High · 2
Medium · 0
Standard · 0
I. Procedural Background
High
⚑ Penalty / liquidated damages
I. Procedural Background The Internal Revenue Service initiated its examination of PPC on May 16, 2022, through the issuance of an initial contact letter (Letter 2205-A) addressed to PPC's VP of Global Tax, Marcus Whitfield. The examination encompasses PPC's federal income tax returns (Forms 1120) filed for tax years ending December 31, 2017, December 31, 2018, December 31, 2019, and December 31, 2020. Throughout the
II. Request for Extension of Time
II. Request for Extension of Time PPC respectfully requests that the deadline to file its formal Protest be extended by fourteen (14) calendar days, from December 8, 2023 to December 22, 2023. PPC submits that good cause exists for this extension, as set forth in detail below.
III. Grounds for Extension — Complexity and Good Cause
High
⚑ Penalty / liquidated damages
III. Grounds for Extension — Complexity and Good Cause A. Extraordinary Complexity of the Proposed Adjustments The proposed adjustments set forth in the NOPA are of extraordinary complexity, both in their legal and economic dimensions. The NOPA encompasses four separate tax years (2017 through 2020) and involves aggregate proposed adjustments of approximately $380.4 million across multiple distinct transfer pricing i
IV. Assurance of Good Faith and Diligence
IV. Assurance of Good Faith and Diligence PPC wishes to assure the Service that this request for a modest extension is made in good faith and is not sought for purposes of delay. PPC has cooperated fully and diligently throughout the examination, responding to all forty-seven (47) IDRs within the timeframes agreed upon with the examination team. At no point during the examination has PPC failed to meet a deadline or
V. Proposed Extended Deadline
V. Proposed Extended Deadline In light of the foregoing, PPC respectfully requests that the deadline to file its formal Protest be extended from December 8, 2023 to December 22, 2023. PPC commits to filing its Protest on or before December 22, 2023, and anticipates no further requests for extension of time.
VI. Contact Information
VI. Contact Information Should you have any questions regarding this request, or should you wish to discuss this matter further, please do not hesitate to contact the undersigned directly: Leonard Cross, Esq. Partner, Tax Department Calderwood & Harkness LLP 1735 Market Street, Suite 3100 Philadelphia, PA 19103 Telephone: (215) 864-7244 Email: lcross@calderwoodharkness.com In addition, a copy of this letter is being