IEPOInternal End Point Object
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After a June 1987 preliminary audit report to the accounting firm in which the IRS confirmed that it was disqualifying IEPO's DISC status and imposing additional tax, a penalty and interest, IEPO sued the firm for accounting malpractice on May 15, 1990.
Although they separately ruled that IEPO suffered actual harm in 1986 when its line of credit was reduced or, at the latest, in June 1987, when the IRS issued a preliminary audit report, the plaintiff's suit was barred by the statute of limitations.
The issue before the court was whether actual harm had occurred before June 1987, when IEPO had sufficient notice of the firm's negligence, or on May 16, 1988, when the IRS assessed the deficiency and penalties against the company.