1018-00009
· Client 1018 · Examination Proceedings
statute-of-limitations-tracking.xlsx
DOCUMENT
M&A / Corporate
[sheet: SOL Tracking]
| Tax Year | Taxpayer Name | EIN | Return Type | Date Filed | Original SOL Expiration | Extension Form | Extension No. | Extension Executed Date | Extended SOL Expiration | Current SOL Expiration | Days Remaining as of 3/29/2024 | IRS Exam Team ID | Examination Status | Notes |
| 2017 | Penterra Pharmaceuticals Corp. | 22-3741856 | Form 1120 | 10/15/2018 | 10/15/2021 | Form 872 | 1 | 09/01/2021 | 12/31/2023 | LB&I-NE-TP-2022-00641 | First extension — required because IRS examination opened 5/16/2022, after original SOL would have expired; extension negotiated in anticipation of exam | |||
| 2017 | Penterra Pharmaceuticals Corp. | 22-3741856 | Form 1120 | 10/15/2018 | 10/15/2021 | Form 872 | 2 | 10/15/2023 | 12/31/2024 | 12/31/2024 | 277 | LB&I-NE-TP-2022-00641 | Closed — Form 906 executed 3/29/2024 | Second extension executed to cover NOPA (10/12/2023), 30-Day Letter (11/8/2023), Protest (12/22/2023), and Appeals proceedings; examination closed 3/29/2024 via Closing Agreement (Form 906) |
| 2018 | Penterra Pharmaceuticals Corp. | 22-3741856 | Form 1120 | 10/15/2019 | 10/15/2022 | Form 872 | 1 | 08/15/2022 | 12/31/2023 | LB&I-NE-TP-2022-00641 | First extension — executed shortly after IRS examination opened 5/16/2022; SOL would have expired 10/15/2022 during IDR period | |||
| 2018 | Penterra Pharmaceuticals Corp. | 22-3741856 | Form 1120 | 10/15/2019 | 10/15/2022 | Form 872 | 2 | 10/15/2023 | 12/31/2024 | 12/31/2024 | 277 | LB&I-NE-TP-2022-00641 | Closed — Form 906 executed 3/29/2024 | Second extension to cover Appeals proceedings; examination closed 3/29/2024 |
| 2019 | Penterra Pharmaceuticals Corp. | 22-3741856 | Form 1120 | 10/15/2020 | 10/15/2023 | Form 872 | 1 | 08/15/2023 | 12/31/2024 | 12/31/2024 | 277 | LB&I-NE-TP-2022-00641 | Closed — Form 906 executed 3/29/2024 | Single extension executed; NOPA issued 10/12/2023 prior to original expiration; extension covers Protest and Appeals; examination closed 3/29/2024 |
| 2020 | Penterra Pharmaceuticals Corp. | 22-3741856 | Form 1120 | 10/15/2021 | 10/15/2024 | N/A — no extension required | 0 | 10/15/2024 | 200 | LB&I-NE-TP-2022-00641 | Closed — Form 906 executed 3/29/2024 | Original SOL sufficient to cover full examination through Appeals; no Form 872 needed; examination closed 3/29/2024 |
[sheet: Extension Detail]
| Tax Year | Extension No. | Form Type | Original SOL Expiration Before This Extension | New SOL Expiration After This Extension | Date Prepared by C&H | Date Executed by PPC | PPC Signatory | PPC Signatory Title | Date Executed by IRS | IRS Signatory | IRS Signatory Title | C&H Matter Number | C&H Responsible Attorney | Reason for Extension | Related Examination Events |
| 2017 | 1 | Form 872 | 10/15/2021 | 12/31/2023 | 08/20/2021 | 08/28/2021 | Marcus Whitfield | VP, Global Tax | 09/01/2021 | Gerald Meskill | Supervisory Revenue Agent, Team Manager | 1018-00009 | Leonard Cross | Extend SOL to permit completion of LB&I transfer pricing examination opened 5/16/2022 | IRS examination opened 5/16/2022; IDR period June 2022 – Sept. 2023 (47 IDRs issued) |
| 2017 | 2 | Form 872 | 12/31/2023 | 12/31/2024 | 10/01/2023 | 10/10/2023 | Marcus Whitfield | VP, Global Tax | 10/15/2023 | Gerald Meskill | Supervisory Revenue Agent, Team Manager | 1018-00009 | Leonard Cross | Extend SOL to permit filing of Protest and completion of IRS Appeals proceedings | NOPA issued 10/12/2023; 30-Day Letter 11/8/2023; Protest filed 12/22/2023; Appeals conference 2/28/2024; settlement 3/22/2024; Form 906 closing agreement 3/29/2024 |
| 2018 | 1 | Form 872 | 10/15/2022 | 12/31/2023 | 07/25/2022 | 08/05/2022 | Marcus Whitfield | VP, Global Tax | 08/15/2022 | Gerald Meskill | Supervisory Revenue Agent, Team Manager | 1018-00009 | Leonard Cross | Extend SOL — original expiration imminent during active IDR period | IDR period ongoing; 47 IDRs issued June 2022 – Sept. 2023 |
| 2018 | 2 | Form 872 | 12/31/2023 | 12/31/2024 | 10/01/2023 | 10/10/2023 | Marcus Whitfield | VP, Global Tax | 10/15/2023 | Gerald Meskill | Supervisory Revenue Agent, Team Manager | 1018-00009 | Leonard Cross | Extend SOL to permit Protest and Appeals proceedings | NOPA 10/12/2023; Protest 12/22/2023; Appeals conference 2/28/2024; Form 906 executed 3/29/2024 |
| 2019 | 1 | Form 872 | 10/15/2023 | 12/31/2024 | 07/25/2023 | 08/05/2023 | Marcus Whitfield | VP, Global Tax | 08/15/2023 | Gerald Meskill | Supervisory Revenue Agent, Team Manager | 1018-00009 | Leonard Cross | Extend SOL — original expiration approaching during final IDR period and anticipated NOPA issuance | Final IDRs Sept. 2023; NOPA 10/12/2023; Protest 12/22/2023; Appeals 2/28/2024; Form 906 executed 3/29/2024 |
[sheet: Key Dates Timeline]
| Date | Event | SOL Status — TY 2017 | SOL Status — TY 2018 | SOL Status — TY 2019 | SOL Status — TY 2020 | Action Required |
| 10/15/2018 | TY 2017 Form 1120 filed (extended due date) | SOL begins — expires 10/15/2021 | N/A | N/A | N/A | None |
| 10/15/2019 | TY 2018 Form 1120 filed (extended due date) | Open — expires 10/15/2021 | SOL begins — expires 10/15/2022 | N/A | N/A | None |
| 10/15/2020 | TY 2019 Form 1120 filed (extended due date) | Open — expires 10/15/2021 | Open — expires 10/15/2022 | SOL begins — expires 10/15/2023 | N/A | None |
| 10/15/2021 | TY 2020 Form 1120 filed; TY 2017 original SOL expires | EXTENDED to 12/31/2023 (Form 872 #1 executed 9/1/2021) | Open — expires 10/15/2022 | Open — expires 10/15/2023 | SOL begins — expires 10/15/2024 | TY 2017 Form 872 #1 already executed |
| 05/16/2022 | IRS examination opened — Letter 2205-A issued (Exam Team LB&I-NE-TP-2022-00641) | Open — extended to 12/31/2023 | Open — expires 10/15/2022 (5 months remaining) | Open — expires 10/15/2023 | Open — expires 10/15/2024 | TY 2018 extension needed promptly |
| 06/02/2022 | C&H engagement letter executed | Open — extended to 12/31/2023 | Open — expires 10/15/2022 | Open — expires 10/15/2023 | Open — expires 10/15/2024 | Prepare TY 2018 Form 872 |
| 06/08/2022 | IRS Form 2848 (Power of Attorney) filed — Cross, Hartwell, Simmons, Nazari authorized | Open | Open | Open | Open | None |
| 06/20/2022 | Kovel letter executed — Whitmore Valuation Group LLC retained | Open | Open | Open | Open | None |
| 08/15/2022 | TY 2018 Form 872 #1 executed by IRS — extended to 12/31/2023 | Open — extended to 12/31/2023 | EXTENDED to 12/31/2023 | Open — expires 10/15/2023 | Open — expires 10/15/2024 | TY 2018 SOL secured |
| 08/15/2023 | TY 2019 Form 872 #1 executed by IRS — extended to 12/31/2024 | Open — extended to 12/31/2023 | Open — extended to 12/31/2023 | EXTENDED to 12/31/2024 | Open — expires 10/15/2024 | TY 2019 SOL secured |
| 10/12/2023 | NOPA issued — $380.4M proposed adjustments (all four years) | Open — extended to 12/31/2023 (expiring soon) | Open — extended to 12/31/2023 (expiring soon) | Open — extended to 12/31/2024 | Open — expires 10/15/2024 | TY 2017 & 2018 need second extensions |
| 10/15/2023 | TY 2017 & TY 2018 Form 872 #2 executed — both extended to 12/31/2024 | EXTENDED to 12/31/2024 | EXTENDED to 12/31/2024 | Open — extended to 12/31/2024 | Open — expires 10/15/2024 | All years secured through 2024 |
| 11/08/2023 | 30-Day Letter issued | Open — extended to 12/31/2024 | Open — extended to 12/31/2024 | Open — extended to 12/31/2024 | Open — expires 10/15/2024 | Protest deadline; extension requested |
| 12/22/2023 | Formal Protest filed | Open — extended to 12/31/2024 | Open — extended to 12/31/2024 | Open — extended to 12/31/2024 | Open — expires 10/15/2024 | Case to be assigned to Appeals |
| 01/2024 | Case assigned to Appeals Officer Noreen Castañeda | Open — extended to 12/31/2024 | Open — extended to 12/31/2024 | Open — extended to 12/31/2024 | Open — expires 10/15/2024 | None |
| 02/28/2024 | Appeals conference — IRS Appeals Office, Manhattan | Open — extended to 12/31/2024 | Open — extended to 12/31/2024 | Open — extended to 12/31/2024 | Open — expires 10/15/2024 | None |
| 03/15/2024 | Settlement offer received from Appeals — $47.6M (12.51% of $380.4M) | Open — extended to 12/31/2024 | Open — extended to 12/31/2024 | Open — extended to 12/31/2024 | Open — expires 10/15/2024 | Client decision required |
| 03/22/2024 | PPC accepted settlement — $47.6M allocated $11.2M/$12.4M/$12.8M/$11.2M across TY 2017–2020 | Open — extended to 12/31/2024 | Open — extended to 12/31/2024 | Open — extended to 12/31/2024 | Open — expires 10/15/2024 | Prepare Form 906 |
| 03/29/2024 | Form 906 Closing Agreement executed — examination closed; penalty fully abated | CLOSED | CLOSED | CLOSED | CLOSED | Matter closed — file amended returns, pay tax ($10.0M) and interest (~$2.84M) |
[sheet: Summary]
| Tax Year | Taxpayer | EIN | Return Type | Original SOL Expiration | Number of Extensions Filed | Final Extended SOL Expiration | Examination Closure Date | Days of Margin at Closure | Settlement Adjustment Allocated | Tax at 21% | Closing Agreement | Status |
| 2017 | Penterra Pharmaceuticals Corp. | 22-3741856 | Form 1120 | 10/15/2021 | 2 | 12/31/2024 | 03/29/2024 | 277 | $11,200,000 | $2,352,000 | Form 906 executed 3/29/2024 | Closed |
| 2018 | Penterra Pharmaceuticals Corp. | 22-3741856 | Form 1120 | 10/15/2022 | 2 | 12/31/2024 | 03/29/2024 | 277 | $12,400,000 | $2,604,000 | Form 906 executed 3/29/2024 | Closed |
| 2019 | Penterra Pharmaceuticals Corp. | 22-3741856 | Form 1120 | 10/15/2023 | 1 | 12/31/2024 | 03/29/2024 | 277 | $12,800,000 | $2,688,000 | Form 906 executed 3/29/2024 | Closed |
| 2020 | Penterra Pharmaceuticals Corp. | 22-3741856 | Form 1120 | 10/15/2024 | 0 | 10/15/2024 (original — no extension needed) | 03/29/2024 | 200 | $11,200,000 | $2,352,000 | Form 906 executed 3/29/2024 | Closed |
| TOTAL | 5 | $47,600,000 | $9,996,000 |