Suijuris Forums - View Single Post - IRS Example-making is alive and well

#2 05-29-2004, 08:42 AM

Yep. It's all about furthering "compliance."

4.10.7.4.5 (05-14-1999)
Compliance
1.The impact on compliance within a segment of the population, sector of the economy, or similarly situated taxpayers will be considered when making a decision whether or not to raise an issue.



4.10.7.4.6 (05-14-1999)
Collectibility
6.Judgment should be exercised when identifying which issues are to be considered "developed." The following areas should be considered in making the decision:
A.The additional time required to complete the issue. Avoid raising an issue unless the audit work is substantially complete.
B.The potential for future non-compliance,
C.The extent of statutory authority. Avoid issues in which the statutory authorities are inconclusive unless there are overwhelming compliance considerations.

Internal Revenue Manual
Part 4. Examining Process
Chapter 12. Nonfiled Returns
Section 1. Nonfiled Returns
4.12.1.3 (05-03-1999)
Enforcement Period
1. Policy Statement P–5–133 in the former IRM 1218 Policy discusses Delinquent Returns and the enforcement of filing requirements. The enforcement period is not to be more than six years. However, the extent to which delinquency procedures will be enforced will depend upon the facts and circumstances of each case and by reference to factors ensuring evenhanded administration of staffing and other Service resources. Enforcement for longer or shorter periods may be used when consideration has been given to:

A. The taxpayer’s prior history of noncompliance
B. The existence of income from illegal sources
C. The effect upon voluntary compliance
D. The anticipated revenue in relation to the time and effort, required to determine tax due.

Randy

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