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Filing an IRC Section 254 Protective Claim for Refund

Generally, a deduction cannot be taken for a claim against the estate while it remains a potential or unmatured claim. Claims that later mature can be deducted on a timely claim for a refund. A protective claim for a refund may be filed pursuant to Treasury Regulation Section 20.2053-1(d)(5) to preserve...

Filing an IRC Section 254 Protective Claim for Refund

Generally, a deduction cannot be taken for a claim against the estate while it remains a potential or unmatured claim. Claims that later mature can be deducted on a timely claim for a refund. A protective claim for a refund may be filed pursuant to Treasury Regulation Section 20.2053-1(d)(5) to preserve...