Improvements to the Office of Chief Counsel’s Published
Guidance Process Would Enhance Guidance Provided to Taxpayers and the Internal
Revenue Service
March 2003
Reference
Number: 2003-10-081
This report has cleared the Treasury
Inspector General for Tax Administration disclosure review process and
information determined to be restricted from public release has been redacted
from this document.
March
31, 2003
MEMORANDUM FOR
CHIEF COUNSEL
FROM: Gordon C. Milbourn III /s/ Gordon C.
Milbourn III
Acting Deputy Inspector
General for Audit
SUBJECT: Final Audit Report - Improvements to the
Office of Chief Counsel’s Published Guidance Process Would Enhance Guidance
Provided to Taxpayers and the Internal Revenue Service (Audit # 200210005)
This
report presents the results of our review of the Office of Chief Counsel’s
published guidance process. The overall
objectives of this review were to determine whether the Office of Chief
Counsel’s published guidance process effectively prioritizes tax issues and
whether management effectively monitors published guidance projects to provide
taxpayers and the Internal Revenue Service (IRS) with timely service. Through the published guidance process, the
IRS and the Department of the Treasury’s Office of Tax Policy issue regulations
and other guidance to interpret and explain the Internal Revenue Code. Published guidance promotes a uniform
understanding and consistent application of the tax laws by taxpayers and the
IRS.
In
summary, the Office of Chief Counsel needs to improve its processes for
prioritizing and tracking tax issues being considered for the published
guidance plan. In addition, the Office
of Chief Counsel needs an effective process to document both the criteria for
selecting the tax issues for publication and the impact of selected tax
issues. Since resources are limited
within the Office of Chief Counsel, it needs to ensure that it is focusing its
efforts on those tax issues most significant to taxpayers and the IRS.
The
Office of Chief Counsel also needs to improve its processes for issuing
published guidance more timely. Our sample of published guidance projects
showed that only 22 percent of the projects were completed by the target date
established at the beginning of the project.
These projects were open for an average of 2.1 years (780 days) and
ranged from being open 20 days to 15.5 years (5,644 days). In addition, the Office of Chief Counsel does not effectively measure the timeliness
of the Published Guidance Program. The
standard used to measure its performance is to complete projects by the end of
the plan year, instead of completing projects by the established target
dates. Without
a meaningful process to monitor the timely issuance of guidance, the Office of
Chief Counsel cannot meet the increasing demands placed upon the Published
Guidance Program. Consequently, delays
in issuing guidance make it difficult for taxpayers to comply with the tax laws
and for the IRS to apply the tax laws in a correct and uniform
manner.
We
recommended that the Office of Chief Counsel implement a process that controls
and documents the tax issues from receipt to disposition. This would include prioritizing
tax issues based on their impact on taxpayers and/or tax administration. We also
recommended that the Office of Chief Counsel implement performance measures
that evaluate the timeliness of the Published Guidance Program and establish a
process that assigns accountability over the circulation and review of proposed
published guidance.
Management’s Response: With regard
to our first recommendation, the Office of Chief Counsel agreed that each
Associate Chief Counsel would maintain files of tax issue requests and
responses and would acknowledge to stakeholders the receipt of tax issue
requests. However, the Office of Chief
Counsel did not agree that other aspects of our recommendation would
significantly advance the published guidance process. With regard to our second recommendation, the Office of Chief
Counsel will consider incorporating into the manual the processes for setting
and monitoring target dates and interim milestones and the processes for
evaluating each Associate Chief Counsel based on the completed projects during
the year. The Office of Chief Counsel
will also study the feasibility of generating a single user-friendly report,
which could be regularly updated to reflect new deadlines and projects. Management’s complete response to the
draft report is included as Appendix V.
Office of Audit Comment: Although
the Office of Chief Counsel acknowledged the importance of selecting and
prioritizing guidance initiatives and focusing limited resources on the most
critical areas, it has only outlined limited actions to improve the
process. The Office of Chief Counsel
has not initiated steps to document the criteria for prioritizing and selecting
projects. Formally documenting the
criteria for selecting and prioritizing projects for the Guidance Priority List
would provide assurances that the tax issues with the most significant impact
on taxpayers and/or tax administration have been accepted. To effectively manage the Published Guidance
Program for timeliness, the Office of Chief Counsel needs to take action to
incorporate these processes into the manual and not merely consider them. In addition, these processes should be
documented to assure implementation of these processes and to assign
accountability for timely completion of the projects.
While we continue to believe
that our recommendation has merit, we do not intend to elevate our disagreement
concerning this recommendation to the Department of the Treasury for
resolution.
Copies of this report are also being sent to the IRS
managers who are affected by the report recommendations. Please contact me at (202) 622-6510 if you have
questions or Daniel R. Devlin, Assistant Inspector General for Audit
(Headquarters Operations and Exempt Organizations Programs) at (202) 622-8500.
Appendix I – Detailed Objectives, Scope, and Methodology
Appendix II – Major Contributors to This Report
Appendix III – Report Distribution List
Appendix IV – List of Published Guidance Projects Reviewed
Appendix V – Management’s Response to the Draft Report
The Office of Chief Counsel is responsible for explaining and providing the correct legal interpretation of the internal revenue laws to its stakeholders. The Published Guidance Program is how the Internal Revenue Service (IRS) and the Department of the Treasury’s Office of Tax Policy (OTP) prioritize the published guidance projects, which interpret and explain the Internal Revenue Code (I.R.C.). The Office of Chief Counsel uses published guidance as the means to promote a uniform understanding and consistent application of the tax laws by taxpayers and the IRS.
The Office of Chief Counsel and the Department of the Treasury’s OTP are responsible for drafting and issuing published guidance. Published guidance consists of regulations, revenue rulings, revenue procedures, and notices, as defined below:
· Regulations – guidance for new legislation and to address issues that arise with respect to the existing I.R.C. sections (e.g., a court decision that invalidates part of a regulation, a new financial product, or an abusive transaction).
· Revenue Rulings – official interpretations of the I.R.C., related statutes, tax treaties, and regulations, as applied to a specific set of facts.
· Revenue Procedures – official statements of procedures that affect the rights or duties of taxpayers or other members of the public under the I.R.C., related statutes, tax treaties, and regulations.
· Notices – public pronouncements that may contain guidance that involve substantive interpretations of the I.R.C. or other provisions of the law.
The IRS’ modernization effort brought about processing changes within the Office of Chief Counsel, including the formation of the Published Guidance Advisory Committee. The Committee is responsible for compiling its list of important projects in the Guidance Priority List (GPL). The GPL was designed to help ensure timely completion of published guidance projects and provides a mechanism for coordinating tax issues among the different business units of the IRS, the Office of Chief Counsel, and the Department of the Treasury’s OTP. This process should result in a GPL that is comprehensive and responsive to taxpayer needs.
Each
year, the IRS publishes a notice in the Internal Revenue Bulletin soliciting
public input on tax issues to be included in the GPL. The IRS also solicits input from the different functions within
the Office of Chief Counsel and the IRS business units. The IRS and the Department of the Treasury’s
OTP use the information to identify and prioritize the tax issues needing
clarification through regulations, rulings, and other published administrative
guidance. Public input is considered an
important part of the process for formulating the GPL to ensure that the IRS’
resources focus on the tax issues that are most important to taxpayers and tax
administration.
Annually, the IRS and the Department of the Treasury’s OTP issue the GPL, identifying the projects targeted for publication during the plan year. For example, the 2001 GPL identified 299 projects targeted for completion by June 30, 2002.
Once the IRS and the Department of the Treasury’s OTP
approve the GPL, the tax issues are established on the Technical Management
Information System (TECHMIS). The
TECHMIS is an automated system designed to provide the Office of Chief Counsel
managers with the tools necessary to work more efficiently and to control and
monitor the progress of published guidance projects.
Upon assignment of a published guidance project, a project legal file is established to provide a record of actions taken and to support decisions made during the development of the guidance. Prior to publication, the proposed guidance is circulated for review and comment within and outside the Office of Chief Counsel.
The audit was performed in the Office of Chief Counsel in Washington, D.C., between January and September 2002. The audit was conducted in accordance with Government Auditing Standards. Detailed information of our audit objectives, scope, and methodology is presented in Appendix I. Major contributors to the report are listed in Appendix II.
The Office of Chief Counsel does not document the process for prioritizing tax issues to be considered for the GPL. Since resources are limited within the Office of Chief Counsel, it needs to ensure that it is focusing its efforts on those tax issues most significant to taxpayers and the IRS. The Published Guidance Advisory Committee reviews suggestions and selects the tax issues to be included for the GPL. However, the Office of Chief Counsel does not record the criteria used by the Committee for selecting the tax issues for publication or document the expected impact of the selected tax issues on taxpayers or tax administration. We also did not find any evidence in the project files or on the TECHMIS indicating the Committee’s basis for selecting a tax issue as a published guidance project.
In addition, the Office of Chief Counsel did not have a process for tracking either suggestions that were not selected or the Committee’s basis for excluding the tax issues in the yearly plan. While about half of the groups in the Office of Chief Counsel maintained a file of suggestions, these suggestions and their impact on taxpayers and tax administration were not centrally maintained for consideration as future published guidance projects.
The Office of Chief Counsel at times needs to address new tax issues after the GPL has been approved. When addressing these tax issues, the Office of Chief Counsel does not have a process to determine the impact the new projects will have on the completion of projects already listed on the GPL. For example, in FY 2001, the Office of Chief Counsel’s technical functions added six projects to the GPL after it was approved. However, these additional projects did not include a justification showing why these projects were a higher priority than other scheduled projects.
Although the Committee had not documented the criteria or the basis for selecting the tax issues, Committee members advised us that published guidance projects were selected when the tax issues:
· Affected a significant number of taxpayers.
· Had a significant impact upon revenue.
· Required a revision of the IRS’ position or procedure as articulated in a published product.
Since the Committee did not keep records on the basis for selecting individual projects, we were unable to determine whether the projects aligned with these criteria.
We believe that formally tracking this process would benefit
the Office of Chief Counsel through enhanced accountability over the
process. Formally documenting the
criteria for selecting projects and retaining a record of the disposition of
each suggested project will provide some assurance that only the tax issues
with the most significant impact on taxpayers and/or tax administration have
been accepted for consideration. The
existing process does not sufficiently provide the Office of Chief Counsel with
this assurance.
An enhanced tracking process would also give the Office of Chief Counsel the ability to provide feedback to customers on the disposition of their suggested tax issues. We believe that initiators of requests for guidance should be informed whether the Office of Chief Counsel will pursue their concerns and when they may expect a response. Alternatively, requesters should be informed when their tax matters will not be pursued so that they may undertake a different course of action.
Finally, centrally tracking requests for guidance and the related dispositions holds forth the opportunity to collect valuable management information. With it, the Office of Chief Counsel may identify and monitor such matters as:
· Collective impact of published guidance projects on taxpayers and the IRS.
· Incremental return from applying additional resources to GPL projects.
· Recurring concerns that come forth over time.
· Cross cutting matters that affect several IRS business units, types of taxpayers, or other stakeholders.
· Implications for the IRS’ business units that result from unresolved tax matters.
It is noteworthy that during the 2000 GPL plan year, the Office of Chief Counsel created a database to control suggestions and provide informative descriptions including the potential impact of the tax issues. However, the Office of Chief Counsel did not update the database to reflect the impacts or dispositions of tax issue suggestions or continue to use the database in subsequent plan years, because it was time consuming to maintain.
1. The Office of Chief Counsel should implement a process that controls and documents tax issues from receipt to disposition. This process should include:
· Formally documenting the criteria for selecting projects.
· Standardizing the format for incoming requests to include information relative to the criteria to facilitate review for inclusion on the GPL.
· Picking the projects that best meet the criteria and maintaining a record of the disposition.
· Keeping a record of who requested the project so that the Office of Chief Counsel staff may follow up with the requester.
· Providing feedback to those whose projects were accepted telling them when to expect a response, and to those whose tax issues were not selected telling them the reason for non-selection.
· Publishing and circulating the GPL to show the benefits and impact of the plan.
· Tracking the requested projects and evaluating the usefulness of this information to the IRS, taxpayers, and other stakeholders.
Management’s Response: The Office of Chief Counsel agreed that each Associate Chief Counsel would maintain files of tax issue requests and the responses to these requests. Management also agreed to provide, as a courtesy, written acknowledgment to stakeholders of the receipt of tax issue requests. The Office of Chief Counsel did not believe that the remainder of the recommendation would significantly advance the published guidance process and would more likely result in burdens that exceed expected benefits.
Office of Audit Comment: Although the Office of Chief Counsel acknowledged the importance of selecting and prioritizing guidance initiatives and focusing limited resources on the most critical areas, they have only outlined limited actions to improve the process.
The Office of Chief Counsel has taken steps to reevaluate the GPL on a quarterly basis, adding projects throughout the year rather than on an annual basis. However, the Office of Chief Counsel has not initiated any steps to document the criteria for prioritizing and selecting projects. Documenting the criteria for prioritizing projects would allow stakeholders to focus published guidance requests and would provide the Published Guidance Advisory Committee the opportunity to weigh additional quantitative data, such as revenue impact or taxpayer burden, when considering proposed projects. Finally, formally documenting the criteria for selecting and prioritizing projects for the GPL would provide assurances that the tax issues with the most significant impact on taxpayers and/or tax administration have been accepted.
The Office of Chief Counsel needs to improve its monitoring process to assure that projects are issued more timely. Our sample of the published guidance projects randomly selected from the 2001 GPL showed that only 7 (22 percent) of 32 of the published guidance projects were completed by the target date established at the beginning of the project. These projects were open, on average, for more than 2.1 years (780 days) and ranged from being open 20 days to 15.5 years (5,644 days).
The amount of time used to complete the published guidance projects was largely dependent upon the type of guidance issued. For example, revenue rulings took an average of 339 days to complete, while regulations took an average of 3.5 years (1,276 days) to complete. The graph below depicts the average number of days it took the Office of Chief Counsel to issue the various types of published guidance for our sample of projects.
The graph was
removed due to its size. To see the
graph, please go to the Adobe PDF version of the report on the TIGTA Public Web
Page.
.
Although projects are planned for completion during the GPL plan year, our sample of published guidance included projects that have been open for years. For example, 1 project had been open for 4.2 years (1,517 days) at the time of our review. The project was initiated to provide guidance on the constructive sale treatment for appreciated financial positions under I.R.C. § 1259. However, we could not assess the impact to either the taxpayer or the IRS caused by the lengthy time to complete the project. This was because the IRS had no record of who requested the guidance and, as a result, we were unable to contact the requester. Further, the IRS did not maintain sufficient information to assess the impact of not timely completing the project.
Another sampled project was initiated to provide guidance on United States taxpayers who transfer property to foreign trusts under I.R.C. § 679. Guidance for this project was issued in July 2001 after it had been open for 12.3 years (4,502 days). Again, we could not identify the requesting party nor could we identify any evidence in the project legal file or the management information system to show the impact of having this project open for over 12 years.
In many instances, delays in issuing published guidance occur because organizations outside the Office of Chief Counsel, including the Department of the Treasury’s OTP and other IRS business units, are required to review the guidance before it can be issued. In one project, the Department of the Treasury’s OTP had proposed guidance for 2 years prior to returning it without comment or concurrence.
A more structured process for circulating and reviewing proposed published guidance is needed to establish accountability for completing the reviews within reasonable time periods. Since the Office of Chief Counsel has primary responsibility for producing the published guidance, it is in the best position to establish reasonable time periods for reviewing guidance internally and for working with other organizations to establish accountability standards, which would assist in ensuring that projects are completed by the established target dates.
In addition, delays occur because the Office of Chief Counsel does not effectively manage the timeliness of the Published Guidance Program. The standard used to measure its performance is to complete projects by the end of the GPL plan year instead of completing projects by the established target dates. Projects that are not completed during the GPL plan year are carried over to the following GPL plan year and new target dates are established. As a result, the target dates are meaningless and are not a concern to those responsible for issuing published guidance.
Between 1992 and 2000, the Office of Chief Counsel reported completing 64 percent of its published guidance projects by the end of the plan year, on average. Since approximately one-third of the projects were carried over from previous GPL plan years and new target dates were established, the reported timeliness was overstated.
Managers in the Office of Chief Counsel used management information system reports to track the due date of the next action required for a project. The managers also periodically met with the assigned attorneys to monitor the progress of projects.
If the Office of Chief Counsel is going to effectively manage for timeliness, it will need to track the original date targeted for completion and establish better accountability standards for completing projects. One standard should require managerial approval when additional time is needed to complete a project. This would provide management the tools necessary to monitor and track the timely completion of projects. This process should also include the use of milestones and interim target dates, and the establishment of standards throughout the review process to create accountability for completing projects within reasonable time periods.
Without
an effective process to monitor the timely issuance of published guidance, the
Office of Chief Counsel cannot meet the increasing demands placed upon the
Published Guidance Program, making it difficult for taxpayers to comply with
the tax laws and the IRS to apply the tax laws in a correct and uniform
manner.
As previously indicated, we attempted to assess the implications of these delays but were unable to do so. The Office of Chief Counsel did not maintain sufficient documentation to determine the impact that delays in completing published guidance projects had on its customers. It had no empirical information to quantify the numbers of taxpayers or stakeholders affected or the dollars involved, with respect to particular guidance projects. However, taxpayers affected by the published guidance, IRS employees who administer the tax laws, and tax professionals who advise and assist taxpayers are all impacted by the untimely completion of published guidance projects.
When we inquired, the Office of Chief Counsel stated that it could not quantify the impact delays had on the customers in the projects we sampled. It stated that even though published guidance projects are selected based on the number of taxpayers affected, the amount of revenue affected, or a revision of the IRS’ position, the Office of Chief Counsel does not require legal project files or its management information system to show the impact of delays on its customers. Also, decisions for issuing published guidance are typically based upon its knowledge of the tax issue involved and, when available, upon the information provided by IRS functions, taxpayers, tax practitioner groups, and others who have suggested the need for guidance.
The Chief Counsel is aware of the delays in issuing published guidance. In an article from the March-April 2002 edition of The Tax Executive, the Chief Counsel expressed his concerns over the amount of time that it was taking to complete published guidance projects and the impact these delays have on tax administration. He believes that the IRS has a public duty to provide timely guidance to taxpayers who are trying to comply with the law. To accomplish this, the Office of Chief Counsel will attempt to issue guidance that addresses the major issues as soon as possible so that the public and the field are aware of the position of the agency.
2. The Office of Chief Counsel should improve its process for issuing published guidance within established time periods by:
· Implementing performance measures which evaluate the timeliness of the Published Guidance Program. This can be accomplished by setting time standards throughout the review process, using milestones and target dates to monitor progress in regard to overall timeliness, and ensuring that project activity is appropriately documented in project legal files and/or management information systems.
· Establishing a process that assigns accountability over the circulation and review of proposed published guidance and for resolving the delays in this process. The process should include standard time periods for circulating and reviewing projects within the Office of Chief Counsel. The Office of Chief Counsel should also work with other organizations, such as the Department of the Treasury’s OTP and the IRS’ business units, in establishing expectations for completing their reviews of the proposed published guidance and operational procedures to intercede when excessive delays occur in the review process.
Management’s Response: The Office of Chief Counsel will consider incorporating into the manual the processes for setting and monitoring target dates and interim milestones and the processes for evaluating each Associate Chief Counsel based on the number, quality, and difficulty of the completed projects during the year. The Office of Chief Counsel will also study the feasibility of generating a single user-friendly report, which could be regularly updated to reflect new deadlines and projects.
The Office of Chief Counsel and the Department of Treasury’s
OTP agreed to implement an expedited guidance process to reduce delays after
the period covered by the TIGTA report.
The expedited guidance process was designed to reduce the amount of
review time spent by the Department of the Treasury’s OTP on projects with no
significant tax policy issues.
Office of Audit Comment: To effectively manage the timeliness of the Published Guidance Program, the Office of Chief Counsel needs to take action to incorporate these processes into the manual and not merely consider them. In addition, these processes should be documented to help assure their implementation and to assign accountability for timely completion of the projects.
Although the expedited guidance process addressed review time in the Department of Treasury’s OTP, the Office of Chief Counsel has not yet initiated actions to resolve delays within the Office of Chief Counsel itself. Implementing procedures within the Office of Chief Counsel as we have recommended will assign accountability for the circulation and review of proposed published guidance.
Appendix I
Detailed Objectives, Scope, and Methodology
The overall objectives of this audit were to determine whether the Office of Chief Counsel’s published guidance process effectively prioritizes tax issues and management effectively monitors published guidance projects to provide the Internal Revenue Service (IRS) and taxpayers with timely guidance. To accomplish our audit objectives, we performed the following audit tests:
I. Interviewed six Associate Chief Counsel personnel, reviewed supporting documentation, and determined whether the Office of Chief Counsel effectively prioritized tax issues to be considered for published guidance projects.
A. Reviewed the inventory listings from the Associate Chief Counsel’s technical units that identifies the tax issues for potential projects and determined the disposition of the tax issues.
B. Reviewed the 2001 Guidance Priority List (GPL) and:
1. Determined the criteria used to prioritize tax administration issues and decide what order the published guidance projects were to be worked.
2. Evaluated the level of input the Office of Chief Counsel had to determine the priority to which published guidance projects were included in the GPL.
3. Determined how adjustments were made to the GPL when the IRS and the Department of the Treasury’s Office of Tax Policy had to respond to developments that occurred during the year.
II. Interviewed a total of 10 Associate Chief Counsel technical unit managers and attorneys, and reviewed a sample of opened and closed published guidance project legal files from the Technical Management Information System 2001 GPL report to evaluate management’s controls for tracking and monitoring the published guidance projects.
A. Determined whether initiated published guidance projects were coordinated to avoid duplication of similar tax issues being addressed by other projects.
B. Reviewed management information reports used to monitor the status of published guidance projects and determined whether target completion dates were established to ensure the guidance was issued timely.
C. Determined whether project legal files were reviewed to ensure that they contained all required documentation and that discrepancies were annotated.
D. Determined whether controls were established to ensure dissenting opinions were addressed, considered, and documented.
E. Determined whether confidentiality procedures were established and followed.
F. Determined how all “interested parties” were identified to ensure their comments and suggestions were incorporated into the final published products.
G. Assessed the impact of tax administration issues not timely published.
H. Determined whether published guidance projects were properly reviewed and approved.
I. Reviewed published guidance projects to ensure they met Federal Register and Internal Revenue Bulletin publication requirements.
III. Evaluated the Office of Chief Counsel’s initiatives to improve the published guidance process and assessed the impact of each initiative.
Appendix II
Major Contributors to This Report
Daniel R. Devlin, Assistant Inspector General for Audit
(Headquarters Operations and Exempt Organizations Programs)
Mary Baker, Director
James V. Westcott, Audit Manager
John Baxter, Senior Auditor
Edward Gorman, Senior Auditor
Marcus D. Sloan, Auditor
Appendix III
Acting Commissioner N:C
Deputy Chief Counsel (Technical) CC
Director,
Office of Program Evaluation and Risk Analysis
N:ADC:R:O
Director, Legislative Affairs CL:LA
Office of
Management Controls N:CFO:F:M
Audit Liaison:
Chief Counsel CC
Appendix IV
Project Description
|
Date Assigned
|
Publication
Date
|
Original Target
Date |
Days Open |
|
|
|
|
|
|
|
Employee Stock Options and Restricted Stock in Section 355 Transactions |
2/2/2000 |
1/14/2002 |
Unknown |
712 |
|
|
|
|
|
|
|
Taxable Asset Acquisitions and Dispositions of Insurance Companies |
10/3/2000 |
3/8/2002 |
Unknown |
521 |
|
|
|
|
|
|
|
Clarification of Section 1.1502-80 |
7/24/2001 |
11/14/2001 |
8/30/2001 |
113 |
|
|
|
|
|
|
|
Alternative Agents of Consolidated Group |
2/18/1999 |
In Progress |
Unknown |
1,132 |
|
|
|
|
|
|
|
Section 368: Mergers of a Corporation With a
Disregarded Entity |
5/15/2001 |
11/15/2001 |
8/30/2001 |
184 |
|
|
|
|
|
|
|
Guidance Under Section 355(e) |
4/5/2000 |
8/3/2001 |
7/30/2001 |
485 |
|
|
|
|
|
|
|
Stock Basis Adjustments |
8/7/2001 |
In Progress |
10/30/2001 |
231 |
|
|
|
|
|
|
|
Section 1259: Constructive Sales Treatment For Appreciated Financial Positions |
1/29/1998 |
In Progress |
Unknown |
1,517 |
|
|
|
|
|
|
|
Conformity Election for Banks Under |
5/4/2001 |
12/17/2001 |
Unknown |
227 |
|
Section 1.166-(2)(D)(3) |
|
|
|
|
|
|
|
|
|
|
|
Securities Futures Contracts |
7/25/2001 |
2/19/2002 |
8/1/2001 |
209 |
|
|
|
|
|
|
|
Section 471: Unit Livestock Price Method of |
5/9/2001 |
2/4/2002 |
11/30/2001 |
271 |
|
Accounting |
|
|
|
|
|
|
|
|
|
|
|
Section 446 and 471: Cash Method of Accounting |
12/12/1997 |
12/26/2001 |
Unknown |
1,475 |
Project Description
|
Date Assigned
|
Publication
Date
|
Original Target
Date |
Days Open |
|
|
|
|
|
|
|
Accounting Period Regulations |
4/9/1999 |
In Progress |
Unknown |
1,082 |
|
|
|
|
|
|
|
Update of Revenue Procedure 87-32 |
5/15/2001 |
6/4/2001 |
5/1/2001 |
20 |
|
|
|
|
|
|
|
Section 162 and 263: Reduction and Capitalization of Expenditures |
5/9/2001 |
1/24/2002 |
9/30/2001 |
260 |
|
|
|
|
|
|
|
Competent Authority Procedure – Update of |
4/14/2000 |
In Progress |
Unknown |
711 |
|
Revenue Procedure 96-13 |
|
|
|
|
|
|
|
|
|
|
|
Nonqualified Intermediaries Notice |
5/1/2001 |
7/23/2001 |
6/30/2001 |
83 |
|
|
|
|
|
|
|
Extraterritorial Income Exclusion Elections |
10/19/2000 |
6/4/2001 |
Unknown |
228 |
|
|
|
|
|
|
|
Revenue Ruling 2001-39 |
3/24/2000 |
8/13/2001 |
Unknown |
507 |
|
|
|
|
|
|
|
Modification to Section 367(a) Stock Transfer |
10/6/1999 |
In Progress |
Unknown |
901 |
|
Regulations |
|
|
|
|
|
|
|
|
|
|
|
Clarification of Entity Classification Rules |
1/21/2000 |
In Progress |
Unknown |
795 |
|
|
|
|
|
|
|
Taxation of Global Trading |
8/21/1990 |
In Progress |
Unknown |
4,235 |
|
|
|
|
|
|
|
Amendment to Revenue Procedure 96-14 |
9/28/2001 |
In Progress |
9/30/2001 |
179 |
|
|
|
|
|
|
|
Foreign Grantor Trusts |
3/23/1989 |
7/20/2001 |
Unknown |
4,502 |
|
|
|
|
|
|
|
Allocation of Loss on Dispositions of Personal Property |
3/17/1998 |
12/28/2001 |
Unknown |
1,382 |
|
|
|
|
|
|
|
Reciprocal Exemptions for Certain Transportation Income |
10/12/1986 |
In Progress |
Unknown |
5,644 |
|
|
|
|
|
|
|
Modification of Revenue Ruling 97-31 |
2/8/2001 |
10/15/2001 |
7/31/2001 |
249 |
Appendix V
The response was removed due to its size. To see the complete response, please go to the Adobe PDF version of the report on the TIGTA Public Web Page.