IRS Demands Taxpayers’ “Help” in Applying Complex Internal Revenue Code


On January 26, 2010, the Internal Revenue Service (“IRS”) published Announcement 2010-9 (the“Announcement”) addressing proposed reporting requirements with respect to uncertain tax positions of certain business taxpayers. According to the Announcement, the IRS is in the process of developing a schedule – to be filed with the annual U.S. federal income tax return – on which certain business taxpayers will be required to disclose their uncertain tax positions affecting their U.S. federal income tax liability. The proposed effective date for the new schedule is for returns filed after its release. The IRS will also issue proposed regulations and is seeking public comments. The new schedule was announced yesterday by IRS Commissioner Douglas Schulmanat a luncheon meeting of the New York State Bar Tax Section in New York City. Schulman started his remarks with discussing the complexity of the tax law and gradually progressed towards arguing in favor of more taxpayer transparency regarding material tax issues in order to help the IRS.

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