In 2019 the IRS audits a company's 2017 tax return and determines that the president's salary was excessive and disallowed $100,000 of the salary deduction.Under the terms of the hedge (payback)agreement in the corporate bylaws,the president repays $100,000 of her salary to her employer in 2017.The president will amend her 2017 tax return to get a refund of the taxes paid on the excess salary.

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The president cannot amend her 2017 tax return because the repayment occurred after the tax year in question. Instead, she may be eligible to claim a deduction or credit for the repayment in the year it was repaid, under the claim of right doctrine.

In 2019 the IRS Audits a Company's 2017 Tax Return