The IRS recently released Schedule UTP filing statistics for the 2011 tax year. The statistics are not complete as returns from some late fiscal year filers and others still have not been processed.
As of December 2012, the IRS was able to report the following:
- 1,783 taxpayers filed Schedule UTP with their 2011 returns
- 83% of all returns with Schedule UTP were filed by taxpayers classified as Industry Case (IC) taxpayers by the Large Business & International (LB&I) Division of the IRS.
- 4,120 uncertain tax positions had been disclosed
- Coordinated Industry Case (CIC) taxpayers disclosed an average of 3.8 uncertain tax positions per Schedule
- IC taxpayers averaged 2.0 uncertain tax positions per Schedule
- 47% of Schedule UTP returns included only one uncertain tax position
2011 also was the first tax year that prior year positions were required to be reported on the Schedule. The IRS has not yet gathered the data to share any statistics to break out the total number of positions reported in the current year and prior years.
No information was released regarding the most frequently reported code sections underlying the uncertain tax positions.
Read more about Schedule UTP here.