In this instance, if the taxpayer has cooperated with all information document requests (IDRs) and provided all requested information, and Examination has poorly developed the case or failed to support conclusions in the revenue agent's report, Appeals can take the case "as is" and resolve it without seeking any additional information or analysis.
The new AJAC procedures put more pressure on Examination to "get it right the first time," before the issuance of the revenue agent's report, because Appeals will no longer send poorly developed cases back for further development and will resolve them on the basis of the poor factual development.
* The date of issuance of the revenue agent's report
and the post-examination critique.
The 60-day letter is generally accompanied by a copy of the revenue agent's report
, outlining the Service's position concerning the proposed adjustments.
For example, assume the taxpayer receives a Revenue Agent's Report
(30- day letter) for $225,000, and that it pays $135,000 of that amount within 30 days.
Unfortunately, the revenue agent's report
makes no mention of the position.
* Retain the current rule requiring protests to be filed within 30 days of the issuance of a Revenue Agent's Report
In addition, the taxpayer will have to pay the assessed tax either with the Revenue Agent's Report
or on or before the last day of the quarter in which the assessment is agreed to.
Although time did not permit a detailed discussion of the return-on-investment (ROI) issue during our Denver meeting, Linda Burke made a critical observation that bears repeating: ROI should not be the predominant measurement factor and, to the extent it is taken into account, the measurement point should not be the date the Revenue Agent's Report
is issued, but rather the end of the administrative (or perhaps even the litigating) process.
Comparison of salaries with distributions: A typical component of the revenue agent's report
is the taxpayer's dividend history (or lack thereof), along with the regulations under Secs.