IEPOInternal End Point Object
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In 1984 the IRS audited IEPO's tax returns and in 1986 advised IEPO that because the firm had failed to provide proper documentation for certain loans, it would disqualify the company as a DISC.
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.