IRS Practice & Procedure

TOPICS

April 1, 2012

Overview of IRS Pre-Appeals Alternative Dispute Resolution Methods

Since the enactment of the Administrative Dispute Resolution Act in 1990, the IRS has been increasingly eager to settle disputes through alternative means such as arbitration and mediation.

April 1, 2012

Supreme Court Considers Regulatory Preference Issue

Can the IRS issue regulations with retroactive effect? That is the central administrative issue in a case pending before the U.S. Supreme Court.

April 1, 2012

PTIN Prop. Regs. for Supervised Nonsigning and Non-1040 Preparers

The IRS issued proposed regulations regarding the availability of PTINs for supervised nonsigning preparers and for preparers of forms other than Form 1040.

April 1, 2012

The RPO, OPR, and Circular 230

A discussion of developments in two critical IRS offices, the Return Preparer Office and the Office of Professional Responsibility.

March 28, 2012

IRS and OECD Separately Address Transfer Pricing Issues

The IRS announced a reorganization of its advance pricing agreement (APA), mutual agreement, and competent authority programs into one new program.

March 26, 2012

TIGTA Calls for Improvements to IRS Volunteer Tax Prep. Program Database

TIGTA reported on its study of the IRS’s monitoring of volunteer tax preparation services.

March 16, 2012

IRS Suspends Repair/Capitalization Exams Pending Accounting Method Changes

The IRS issued a directive for field examinations on the repair vs. capitalization issue that essentially suspended current examinations so as to permit taxpayers to file accounting method changes under just-issued revenue procedures.

March 14, 2012

Prop. Regs. Would Require Taxpayers That Received EINs to Update Information

The IRS issued proposed regulations that would require taxpayers that obtain employer identification numbers (EINs) to update their information with the IRS.

March 7, 2012

IRS Expands “Fresh Start” Initiative, Provides Penalty Relief for Unemployed

The IRS announced an expanded “Fresh Start” initiative to help struggling taxpayers with a number of measures for relief.

March 1, 2012

IRS Chief Counsel: Continue Applying Valuation Misstatement Penalties

The IRS recently addressed the application of the valuation misstatement penalties contained in Secs. 6662(b)(3) and 6662(h).

March 1, 2012

EITC Due-Diligence Final Regs. Issued

The IRS issued final regulations governing the due-diligence requirements imposed on tax return preparers who prepare tax returns on which taxpayers claim the earned income tax credit.

March 1, 2012

ODC Tax Liability and Audit Information Cannot Be Disclosed

The Federal Circuit held that audit tests and related information of third-party taxpayers pertaining to the assessment of the ozone-depleting chemicals excise tax was return information not subject to disclosure under Sec. 6103(a).

February 28, 2012

IRS Regulations Broaden Disclosures of Tax-Exemption Determinations

The IRS issued final regulations regarding disclosure of denials and revocations of tax-exempt status.

February 28, 2012

Correspondence Audits Need Some Work, Tax Community Tells IRS

Correspondence audits were the subject of a public hearing by the IRS Oversight Board.

February 27, 2012

FinCEN Postpones Mandatory FBAR E-Filing

FinCEN announced that it is postponing until July 1, 2013, its requirement that FBARs be filed electronically.

February 22, 2012

Supreme Court: Filing a False Tax Return Can Lead to Deportation

The Supreme Court held that a conviction under Sec. 7206 for willfully filing a false tax return (or for aiding and abetting filing a false tax return) is an aggravated felony that can result in deportation.

February 14, 2012

IRS Proposes PTIN Regs. for Supervised, Nonsigning and Non-1040 Preparers

The IRS issued proposed regulations regarding the availability of PTINs for supervised nonsigning preparers and for preparers of forms other than Form 1040. They also address what tax forms are considered returns for purposes of the PTIN rules.

February 13, 2012

President’s Budget Proposes AMT Elimination, Tax Reform

President Barack Obama unveiled his proposed budget for FY 2013. It includes several tax reform proposals, including plans to eliminate the AMT, to repeal LIFO, and to tax dividends of high-income taxpayers at ordinary income rates.

February 7, 2012

TIGTA: Revise Form 1099-R to Improve Taxpayer Compliance

TIGTA recommended the IRS change its Form 1099-R to improve taxpayer compliance with reporting and paying tax on retirement income

February 6, 2012

Couples Who Filed Joint Returns Must Now File Separate Powers of Attorney

The new version of the IRS power of attorney form requires a husband and wife who filed a joint tax return to each file a separate power of attorney on separate forms to designate the representative he or she chooses, even if it is the same person.