In a Form 8-K filed with the SEC, Microsoft said it will appeal the finding made under a Notice of Proposed Adjustment, which stem from an ongoing tax audit and the disposition can take several years. In a blog post, Daniel Goff, corporate VP of worldwide tax and customs said the disagreement stems from the way Microsoft allocated profits during this time period among countries and jurisdictions. Goff wrote that Microsoft has always followed IRS rules and believes it paid the appropriate amount of taxes in the country and elsewhere. Goff noted the $28.9 billion does not represent a final determination and Microsoft expects that under Tax Cuts and Jobs Act the amount owed may be cut by up to $10 billion. The company stated it believe its allowances for income tax contingencies are adequate and since no resolution is expected over the next year, it does not expect a significant increase or decrease to our tax contingencies during that time.