QUIGGLE & LIPMAN REDMAN, PROCEDURE BEFORE THE
INTERNAL REVENUE SERVICE 86 n.47 (6th ed.
On December 17, 2004, the Treasury Department published final regulations amending the tax shelter provisions of Circular 230, which imposes duties on practitioners representing taxpayers before the
Internal Revenue Service. Scheduled to become effective on June, 20, 2005, these regulations represent the most recent development in the Treasury Department's continuing effort to deter abusive tax shelters and otherwise enhance professionalism among tax practitioners.
In a major escalation of AU's "Project Fair Play," the organization announced last September that it will begin reporting churches that distribute the Christian Coalition's voter guides -- or other similarly biased guides from other organizations -- to the
Internal Revenue Service. At the same time, AU has stepped up its efforts to educate religious leaders about the dangers of partisan political activity in houses of worship.
The
Internal Revenue Service Restructuring and Reform Act (HR 2676) would create an oversight body (composed of eight private-sector members, the secretary of the treasury, a representative from a union representing a substantial number of IRS employees and the IRS commissioner) to oversee IRS administration, management, conduct, direction and supervision of the execution and application of the Internal Revenue Code.
On behalf of Tax Executives Institute, I am writing to applaud the revisions to the final regulations amending Circular 230 governing practice before the
Internal Revenue Service that were released on May 18, 2005.
Wrote Lynn to Rossotti, "The
Internal Revenue Service bears the responsibility of ensuring that tax-exempt status is not abused by partisan political groups such as the Christian Coalition.
(1) IN GENERAL.--In any noncriminal proceeding before the
Internal Revenue Service, the taxpayer shah be entitled to the same common law protections of confidentiality with respect to tax advice furnished by any qualified individual (in a manner consistent with State law for such individual's profession) as the taxpayer would have if such individual were an attorney.
(65) Circular 230 defines "practice before the IRS" as encompassing "all matters connected with a presentation to the
Internal Revenue Service," including preparing and filing returns and documents, corresponding and communicating with the IRS, and representing a client at conferences, hearings, and meetings.
This practice is particularly common in 401 (k) plans, and the
Internal Revenue Service has acknowledged that such plans are particularly high on their audit list.
26,1997 hearing of the National Commission on Restructuring the
Internal Revenue Service. In its written testimony, the Institute discussed, and proposed solutions for, over 20 current taxpayer rights issues.
Persons With Respect to Foreign Disregarded Entities, filed with the
Internal Revenue Service (3/2/04).
The
Internal Revenue Service released final rules implementing a number of miscellaneous provisions of the Taxpayer Bill of Rights 2 and an amendment in the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 that affect filing of returns, court costs, payments, deposits and collections.