Daily Tax Report Index-Summary

See also INTERNAL REVENUE SERVICE (IRS)
– Appeals impartiality, office space, TAS official raises concerns, 8:G–3 (1/14/10)
– Business entities, proposed check-the-box modifications for foreign entities, Viewpoint, 5:J–1 (1/11/10)
– Collection

See TAX COLLECTION

– Communication with taxpayers, IRS redesigns 9 notices, 6:G–2 (1/12/10)
– Compliance programs

See TAX COMPLIANCE; TAX GAP

– Customer service

– – GAO spotlights areas for congressional, IRS action before 2010 filing season, 6:G–3 (1/12/10)
– – Telephone service tops problems Taxpayer Advocate cites, annual report, 3:G–4 (1/7/10)
– – 2010 filings, IRS fact sheets address resources, issues for taxpayers to consider, 1:G–5 (1/5/10)

– Dispute resolution

– – Fast-track settlements, ABA tax section panel on, 15:G–5 (1/26/10)
– – Offers in compromise program

See TAX COLLECTION

– Effectiveness, agency versatility becoming themes, Chief Counsel says, 15:G–1 (1/26/10)
– Enforcement

See TAX ENFORCEMENT

– Examinations

See TAX AUDITS

– FOIA disclosures

See FREEDOM OF INFORMATION ACT (FOIA)

– FY2009 challenges, accomplishments, Treasury report, 1:G–6 (1/5/10)
– Health care reform, IRS cannot handle new duties, Grassley (R-Iowa) warns, 4:G–2 (1/8/10)
– Internal Revenue Manual, IRS posts list of all IRM changes effective Jan. 1, 2:G–7 (1/6/10)
– Legal advice, informal, Chief Counsel releases e-mail, 1:K–3 (1/5/10); 10:K–2 (1/19/10); 14:K–2 (1/25/10)
– Notice, IRS seeks public comment, 10:G–2 (1/19/10)
– Privacy issues

See PRIVACY

– Questionable refund review, TIGTA addresses transfer of responsibility, 7:G–3 (1/13/10)
– Regulation projects

See REGULATIONS

– Return filing

See ELECTRONIC FILING; TAX RETURNS

– Revenue Procedures, OMB review sought, 14:G–2 (1/25/10)
– Rulings and technical advice

– – Determination letters for employee plans

See PENSIONS

– – Exempt status rulings

See EXEMPT ORGANIZATIONS

– – General guidance, IRS updates procedures for issuing, 1:G–2 (1/5/10); Rev. Proc. 2010-1 on letter rulings, information letters, determination letters, 1:TaxCore (1/5/10); Rev. Proc. 2010-2 on obtaining technical advice, 1:TaxCore (1/5/10)
– – International, index for Appeals technical guidance online, 7:G–8 (1/13/10)
– – Issues ineligible for rulings, IRS updates lists, 1:G–3 (1/5/10); domestic areas, Rev. Proc. 2010-3, 1:TaxCore (1/5/10); international areas, Rev. Proc. 2010-7, 1:TaxCore (1/5/10)
– – Redaction, issuance of private letter ruling (T.C.), 11:K–3 (1/20/10); decision text, 11:TaxCore (1/20/10)

– Statistics

See STATISTICS

– Taxpayer advocacy panels

See TAXPAYER ADVOCACY PANELS

– Taxpayer Advocate report lists problems, 3:G–4 (1/7/10); executive summary, 3:TaxCore (1/7/10); annual report to Congress, 3:TaxCore (1/7/10)
– 2010 filing season

See TAX RETURNS

– User fee schedule revised for employee plans, exempt organizations, 1:G–4 (1/5/10)
– Whistleblowers

See TAX ENFORCEMENT

TAX AUDITS

– Corporate audits

– – Accounting method change for repairs, capitalization, IRS designates as Tier 1 issue, 16:G–2 (1/27/10)
– – Paper documents still sought despite e-filing mandate, 15:G–8 (1/26/10)

– Deliberative privilege, judge rules on claims in dispute over $1B charitable deduction (S.D. Ohio), 2:K–1 (1/6/10); Proctor & Gamble decision, 2:TaxCore (1/6/10)
– Employer appointments, NRP audit letters will go out in late Feb., 15:G–7 (1/26/10); focus of audits, 16:G–4 (1/27/10); SBSE Deputy Comm'r Fink describes NRP program, 16:G–12 (1/27/10)
– IRS posts audit technique guides on multiple issues, 16:G–13 (1/27/10)
– Swaps avoiding dividend tax, IRS guidance, 11:G–5 (1/20/10)
– Universal service funds, USF abuse reduced from active Tier 1 issue to monitoring status, 3:G–6 (1/7/10)

TAX COLLECTION

– Assessment period extensions, interim guidance for Appeals employees, 11:G–1 (1/20/10)
– Bankruptcy, Chap. 11 default, tax collection after, CCA, 14:K–1 (1/25/10)
– Burden of proof 10-year collection limitations waiver (T.C.), 6:K–1 (1/12/10); decision text, 6:TaxCore (1/12/10)
– Collection due process, suspending collection, ABA teleconference, 8:G–3 (1/14/10)
– Corporate officer personally responsible for federal tax liability (4th Cir.), 8:K–2 (1/14/10); decision text, 8:TaxCore (1/14/10)
– Government contractors

See GOVERNMENT CONTRACTS AND CONTRACTORS

– Liens

– – Automated process, Taxpayer Advocate raises concern, annual report, 3:G–4 (1/7/10)
– – Subordination to security interest of lender, IRS reissues guidance, 1:G–7 (1/5/10); SBSE memorandum, 1:TaxCore (1/5/10)

– Offers in compromise

– – Guidance reissued, posted, 17:G–6 (1/28/10); real property valuations, 17:TaxCore (1/28/10); accepted offers, 17:TaxCore (1/28/10)
– – IRS delegation order, 11:G–10 (1/20/10)

– Private debt collection, TIGTA reports on steps IRS took to end program, 10:G–2 (1/19/10)
– Revenue collection in FY2010, CBO forecast, 16:G–1 (1/27/10)
– Withholding

See WITHHOLDING TAXES

TAX COMPLIANCE

See also TAX GAP
– Offshore assets, disclosing

See OFFSHORE HAVENS

– S corporation reporting of shareholder basis, GAO urges legislation, 9:G–4 (1/15/10)
– Worker classification

See EMPLOYMENT TAXES

TAX COURT

– Electronic filing, case inventory, Chief Judge discusses, 16:K–1 (1/27/10)
– Son of BOSS case, court has jurisdiction in FPAA challenge (D.C. Cir.), 7:K–1 (1/13/10); decision text, 7:TaxCore (1/13/10)

TAX CREDITS

See CREDITS AGAINST TAXES

TAX ENFORCEMENT

– Abusive shelters

See TAX SHELTERS

– Church inquiries

See EXEMPT ORGANIZATIONS

– Criminal Investigations biggest focus international, 15:G–6 (1/26/10)
– Foreign accounts

See OFFSHORE HAVENS

– Fraud and tax evasion

See TAX FRAUD

– Government contracts blocked for tax delinquents, 12:G–1 (1/21/10); White House memorandum, 12:TaxCore (1/21/10)
– IRS audits

See TAX AUDITS

– Whistleblowers

– – Claim procedures, privacy protection, developing guidance, 16:G–8 (1/27/10)
– – UBS former banker Birkenfeld

See SWITZERLAND

TAX EXCLUSIONS

– Damages from physical injuries or sickness, hearing set on exclusion rules, 5:G–3 (1/11/10)
– Smart grid grants

See UTILITIES

TAX-EXEMPT BONDS

See BONDS, EXEMPT

TAX-EXEMPT ORGANIZATIONS

See EXEMPT ORGANIZATIONS

TAX FORMS

– Benefit plans, Form 5500

See EMPLOYEE BENEFITS

– Excise taxes, OMB to review TTB forms, 10:G–7 (1/19/10)
– First-time home buyers

See HOUSING

– OMB review of various forms sought, 8:G–9 (1/14/10); 14:G–2 (1/25/10); 16:G–13 (1/27/10)
– Public comment sought on forms, 10:G–2 (1/19/10)

TAX FRAUD

See also TAX SHELTERS
– Adelphia Communications founder, en banc rehearing granted on double jeopardy issue (3d Cir.), 9:K–2 (1/15/10); decision text, 9:TaxCore (1/15/10)
– California

– – CEO pleads guilty to filing false return (C.D. Cal.), 8:K–3 (1/14/10)
– – OID refund of $5M, Cal. man pleads guilty to fraud (N.D. Cal.), 7:K–3 (1/13/10)
– – Refunds for deceased persons, Cal. man pleads guilty (C.D. Cal.), 16:K–4 (1/27/10)
– – San Francisco commercial landlord pleads guilty to tax charges (N.D. Cal.), 18:K–5 (1/29/10)

– Embezzler's conviction of bank fraud, tax evasion affirmed (6th Cir.), 12:K–1 (1/21/10); decision text, 12:TaxCore (1/21/10)
– Frivolous lawsuits, DOJ seeks to bar National Justice Center scheme (M.D. Tenn.), 8:K–1 (1/14/10); complaint text, 8:TaxCore (1/14/10)
– Online scams impersonating IRS, fact sheet, 1:TaxCore (1/5/10)
– Ozone depleting gas, CFC seller convicted of excise tax fraud (E.D.N.Y.), 18:K–5 (1/29/10)
– Printing firm owners pleads guilty to tax conspiracy charge (D-Mass), 11:K–5 (1/20/10)
– Pyramid scheme, conviction upheld (5th Cir.), 16:K–1 (1/27/10); decision text, 16:TaxCore (1/27/10)
– Questionable refund review, TIGTA addresses transfer of responsibility, 7:G–3 (1/13/10)
– Real estate agent pleads guilty to tax evasion (M.D. Fla.), 12:K–3 (1/21/10)
– Return preparers

– – Cal preparer admits to fraudulent practices (C.D. Cal.), 4:K–2 (1/8/10)
– – DOJ seeks injunctions barring 13 tax preparers in 4 states, 4:K–1 (1/8/10); complaint filed against Ga. preparer, 8:K–3 (1/14/10)
– – Redemption scheme, Idaho tax preparer shut down (D. Idaho), 2:K–3 (1/6/10)
– – Tenn. woman barred from preparing returns (M.D. Tenn.), 18:K–5 (1/29/10)

– Sentencing

– – Attorneys, high lifestyle nets year-long suspension for 2 lawyers (N.Y. App. Div.), 3:K–2 (1/7/10)
– – Bronx man, fraudulent refunds (S.D.N.Y.), 5:K–8 (1/11/10)
– – Miami men sentenced for tax preparation fraud (S.D. Fla.), 7:K–3 (1/13/10)
– – Probation sentence not reasonable in tax evasion case (4th Cir.), 8:K–2 (1/14/10); decision text, 8:TaxCore (1/14/10)
– – UBS clients sentenced for foreign accounts with bank (W.D. Wash.) (D.N.J.), 9:K–2 (1/15/10)

– Solar energy credits, partial summary judgment (D. Haw.), 1:K–1 (1/5/10); decision text, 1:TaxCore (1/5/10)
– Tax havens

See OFFSHORE HAVENS

– Va. businessman pleads guilty to tax charge (E.D. Va.), 13:K–3 (1/22/10)

TAX GAP

– CRS issue statement, 13:G–1 (1/22/10)
– S corporation shareholder basis reporting, GAO urges legislation, 9:G–4 (1/15/10)
– Stock basis reporting

See INFORMATION REPORTING

TAX LEGISLATION

– Bank executive bonuses

See LEGISLATION, FEDERAL, HR 4426

– COBRA subsidy

See LEGISLATION, FEDERAL, HR 3326*

– Estate tax relief

See ESTATE TAX

– Expiring tax provisions

See LEGISLATION, FEDERAL, HR 4213

– Foreign banks, trusts, reporting

See LEGISLATION, FEDERAL, HR 4213

– Haitian relief

See LEGISLATION, FEDERAL, HR 4462*, S 2936, S 2937

– Health care reform bills

See HEALTH CARE REFORM

– Job creation

See EMPLOYMENT AND UNEMPLOYMENT

– Major tax issues before Congress, CRS issues report, 1:G–3 (1/5/10); text, 1:TaxCore (1/5/10)
– Outlook 2010, BNA Special Report, 10:SplRpt (1/15/10); legislative priorities, correction, 11:G–10 (1/20/10)
– Wall St. tax

See LEGISLATION, FEDERAL, HR 4191, S 2927

– Worker classification loophole

See LEGISLATION, FEDERAL, S 2882

TAX POLICY AND REFORM

See also TAX LEGISLATION
– AMT relief

See ALTERNATIVE MINIMUM TAX (AMT)

– Business tax incentives not effective in boosting growth, jobs, CRS says, 16:G–4 (1/27/10)
– Corporate tax rate, NAM reform priorities, 16:G–7 (1/27/10)
– Energy tax policy

– – Issues before Congress, CRS report, 1:TaxCore (1/5/10)
– – Solar, wind energy

See RENEWABLE ENERGY

– Estate tax relief

See ESTATE TAX

– Financial crisis responsibility fee

See FINANCIAL INDUSTRY STABILIZATION, subheading: Bank risk-taking

– Health care reform

See HEALTH CARE REFORM

– Internet commerce

See ELECTRONIC COMMERCE

– Investment income, CRS statement on taxation, 13:G–1 (1/22/10)
– Key challenges, accomplishments in FY2009, Treasury report, 1:G–6 (1/5/10)
– Middle class initiatives

– – Obama previews State of the Union address, 15:GG–1 (1/26/10); White House fact sheet, 15:TaxCore (1/26/10); tax relief pledge, 18:GG–2 (1/29/10)
– – Tax cuts, pay-go exemption

See LEGISLATION, FEDERAL, HJRes 45

– Multinational issues

See INTERNATIONAL TAX

– Tax cuts to expire

– – Average tax rate to rise 2.3 points, JCT estimates, 8:G–9 (1/14/10)
– – GDP, deficit impact of extension, CBO analysis, 17:G–5 (1/28/10); Dir. Elmendorf's remarks to House Budget Comm., 17:TaxCore (1/28/10)
– – Pay-go exemption, middle-class tax cuts

See LEGISLATION, FEDERAL, HJRes 45

– – Senate Budget Comm. investigates impact of extending 2001, 2003 cuts, 18:G–6 (1/29/10)
– – Top rate of 35 percent, GOP lawmakers argue to retain, 14:G–10 (1/25/10); Obama says nation can't afford tax break, 18:GG–2 (1/29/10)

– Tax expenditures, JCT says health benefits, mortgage interest cost most, 6:G–5 (1/12/10)
– Tax gap issues

See TAX GAP

TAX PRACTICE

– Accuracy-related penalties, disclosure needed, 17:G–6 (1/28/10); IRS Rev. Proc. 2010-15, 17:TaxCore (1/28/10)
– Circular 230 revisions, preparer responsibilities, OPR Dir. Hawkins on, 14:G–9 (1/25/10)
– Disclosures, taxpayer authorization, comment sought on expanded period, 1:G–1 (1/5/10); IRS news release, 1:TaxCore (1/5/10)
– Due diligence

– – IRS sample letter to return preparers, 16:TaxCore (1/27/10)
– – Practitioner discipline, OPR Dir. on, 14:G–8 (1/25/10)

– Enforcement, OPR Dir. describes “soft” approach, 16:G–11 (1/27/10)
– Forms and instructions

See TAX FORMS

– Interest rates

See INTEREST RATES

– IRS former executives Stiff, Shott join PricewaterhouseCoopers, 18:G–9 (1/29/10)
– Offers in compromise program

See TAX COLLECTION

– Penalty regime reform, ABA panel discussion, 18:G–4 (1/29/10)
– Regulation of return preparers

See RETURN PREPARERS

– Roth IRA conversions, policy research policy group weighs advantages, 1:G–4 (1/5/10)
– Tax accrual work payers, Textron appeal

See SUPREME COURT, U.S.

– Telephone directory for IRS attorneys, by Code section, subject updated, 4:G–6 (1/8/10)
– Uncertain tax positions, disclosure

See ACCOUNTING

TAX PREPARERS

See RETURN PREPARERS

TAX RETURNS

See also ELECTRONIC FILING
– AMT relief

See ALTERNATIVE MINIMUM TAX (AMT)

– EITC claims

See EARNED INCOME TAX CREDIT (EITC)

– Exclusions from gross income

See TAX EXCLUSIONS

– Foreign financial accounts, reporting

See INFORMATION REPORTING

– Forms

See TAX FORMS

– Fraud schemes

See TAX FRAUD

– Making Work Pay credit, IRS fact sheet, 1:TaxCore (1/5/10)
– Online scams impersonating IRS, fact sheet, 1:TaxCore (1/5/10)
– Paid return preparers

See RETURN PREPARERS

– Refunds, direct deposit, bond purchase, IRS fact sheet, 1:TaxCore (1/5/10)
– 2010 filing season

– – Accuracy-related penalties, disclosure needed, 17:G–6 (1/28/10); IRS Rev. Proc. 2010-15, 17:TaxCore (1/28/10)
– – Free tax help, IRS resources, fact sheet, 1:TaxCore (1/5/10)
– – GAO spotlights areas for congressional, IRS action, 6:G–3 (1/12/10)
– – Haitian relief, 2009 deductions

See LEGISLATION, FEDERAL, HR 4462*, S 2936

– – Home buyers' credit claims

See HOUSING

– – Spanish-speaking taxpayers, IRS, Telemundo host TV show, 11:G–9 (1/20/10)
– – Tax law changes for 2009 tax year, IRS fact sheet, 1:TaxCore (1/5/10)

TAX SHELTERS

– Ernst & Young former partners sentenced to prison (S.D.N.Y.), 13:K–2 (1/22/10); 2 additional former partners sentenced, 14:K–5 (1/25/10)
– FLIP shelter, fact disputes bar ruling on PwC, E&Y negative causation defense (E.D. Wash.), 15:K–2 (1/26/10)
– Ill. extends penalty waiver for taxpayers that miscalculated interest, 17:H–4 (1/28/10)
– Innocent spouse relief claim dismissed (9th Cir.), 13:K–1 (1/22/10); decision text, 13:TaxCore (1/22/10)
– Offshore tax havens

See OFFSHORE HAVENS

– Son of BOSS case, Tax Ct. has jurisdiction in FPAA challenge (D.C. Cir.), 7:K–1 (1/13/10); decision text, 7:TaxCore (1/13/10)
– Swiss bank probe

See SWITZERLAND

– VEBA, no ERISA remedy for false advice (C.D. Ill.), 11:K–3 (1/20/10); decision text, 11:TaxCore (1/20/10)
– Wells Fargo used SILO shelter, $115M refund claim denied (Fed. Cl.), 5:K–6 (1/11/10); decision text, 5:TaxCore (1/11/10)

TAX TREATIES

– Chile, U.S. complete negotiations, 16:I–1 (1/27/10)
– Consular employees subject to tax, U.S.-German agreement, 5:I–1 (1/11/10); IRS Ann. providing text of protocol, 5:TaxCore (1/11/10)
– Exchange of tax information

See OFFSHORE HAVENS

– LLPs, Netherlands, Japan revise treaty to close major loopholes, 7:I–2 (1/13/10)
– Permanent establishments, business groups welcome OECD Article 7 changes, 18:I–5 (1/29/10)

TAXPAYER ADVOCACY PANELS

– Feb. meetings announced, 15:G–3 (1/26/10); Area 6 TAP, 17:G–8 (1/28/10)

TELECOMMUNICATIONS

– Employer-provided cell phones

See TRADE OR BUSINESS EXPENSES

– Internet service

See INTERNET

– S.D. tax overpayment, wireless company may seek hearing (S.D.), 14:K–3 (1/25/10); decision text, 14:TaxCore (1/25/10)

TELEVISION AND RADIO

– Satellite TV, local taxes on providers preempted (U.S., rev den), 6:K–1 (1/12/10)

TERRITORIES, U.S.

See specific territories

TEXAS

– Environmental systems, appraisal district must adjust property value, sanctions assessed (Tex. App.), 17:K–2 (1/28/10); decision text, 17:TaxCore (1/28/10)
– Hotel reservations, Houston's claims against online travel firm dismissed (Tex. Dist. Ct.), 13:K–3 (1/22/10); decision text, 13:TaxCore (1/22/10)

TOBACCO INDUSTRY

– Online purchases, New York City's RICO claims dismissed (U.S., judg rvs), 15:K–1 (1/26/10); decision text, 15:L–1 (1/26/10)

TRADE OR BUSINESS EXPENSES

– Capitalization rules

See CAPITALIZATION

– Cell phones, substantiation of business use, Congress expected to provide relief, 6:G–3 (1/12/10)
– Executive pay

See EXECUTIVE COMPENSATION

TRANSFER PRICING

– Arm's-length standard, IRS official, panelists discuss issues, 6:G–1 (1/12/10)
– Brazil introduces new method, rule changes, 17:I–3 (1/28/10)
– Canada appeals ruling allowing breaks for GE guarantee fees, 8:I–2 (1/14/10)
– Developing countries, OECD announces new task force, 18:I–4 (1/29/10)
– European Union code of conduct to avoid double taxation, changes adopted, 1:I–3 (1/5/10)
– Financial guarantees, IRS studying several issues, 14:G–12 (1/25/10)
– France documentation rules threshold 400M euros, 4:I–3 (1/8/10)
– Japan to clarify pricing goals with FY2010 tax reforms, 3:I–1 (1/7/10)
– OECD guidelines, TEI supports draft revisions, cites concerns, 8:I–1 (1/14/10)
– Statistics FY2009, foreign-initiated adjustments, APAs, 9:G–2 (1/15/10); IRS report, 9:TaxCore (1/15/10)
– Xilinx stock options, controversial opinion withdrawn (9th Cir.), 8:K–1 (1/14/10); decision text, 8:TaxCore (1/14/10)

TRANSPORTATION

– Airlines

See AIR TRANSPORTATION

– Automobiles

See MOTOR VEHICLES

– Maritime

See SHIPS AND SHIPPING

– State improvements, funding

See specific states

– Trust fund extension in Senate jobs bill, 17:G–1 (1/28/10)

TREASURY DEPARTMENT

– Personnel

– – Caballero takes key international post, 14:G–15 (1/25/10)
– – Crnkovich named senior counsel for partnerships, 8:G–3 (1/14/10)
– – Senate Finance Comm. questionnaire for vetting nominees, Grassley (R-Iowa) releases, 8:G–3 (1/14/10)

TREATIES

See TAX TREATIES

TROUBLED ASSET RELIEF PROGRAM (TARP)

See FINANCIAL INDUSTRY STABILIZATION
– Compensation limits

See EXECUTIVE COMPENSATION

TRUSTS

– Foreign trusts

– – Penalty for failure to file information, 12:G–4 (1/21/10); SBSE memorandum, 12:TaxCore (1/21/10)
– – Reporting

See LEGISLATION, FEDERAL, HR 4213