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The IRS has released 2011 statistics for filings of Schedule UTP (Uncertain Tax Positions) through December 2012, and reissued 2010 UTP statistics.

IRS Provides Updated Filing Statistics On Schedule UTP

  • 2/20/2013

IRS Provides Updated Filing Statistics on Schedule UTP

The IRS has released tax year 2011 statistics for filings of Schedule UTP (Uncertain Tax Positions) through December 2012, and reissued tax year 2010 UTP statistics for comparison.

Schedule UTP requires information on tax positions that affect the federal income tax liabilities of corporations that recorded a reserve with respect to that position in an audited financial statement. A corporation must file Schedule UTP if it files a Form 1120, 1120-F (foreign), 1120-L (life insurance), or 1120-PC (property and casualty).

For 2011, 1,783 taxpayers have filed Schedule UTP:

  • 17 percent were filed by coordinated issue cases (CIC) (taxpayers that are always under audit)
  • 83 percent were filed by other taxpayers
  • Taxpayers have reported a total of 4,120 tax positions, an average of 2.3 positions per return
  • CIC taxpayers averaged 3.8 positions per return
  • Other taxpayers averaged two positions per return
  • 47 percent reported only one uncertain tax position

For 2010, 2,356 taxpayers filed Schedule UTP:

  • 21 percent were filed by CIC taxpayers
  • 79 percent were filed by other taxpayers
  • Taxpayers disclosed 4,712 positions, an average of exactly two positions per return
  • CIC taxpayers averaged 3.1 positions per return
  • Other taxpayers averaged 1.9 positions per return
  • 49 percent of all taxpayers reported only one uncertain tax position

The top three tax code sections reported by Schedule UTP filers were Code Sections 41 (research credit), 482 (transfer pricing), and 162 (trade or business expenses). The third highest primary section is Code Section 263 (capitalization). Code Sections 41 and 482 totaled 43 percent of all disclosed positions.

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