Statement on the Improved Penalty Administration and Compliance Tax Act (H.R. 2528), June 6, 1989.
June 6, 1989
Mr. Chairman and Members of the Subcommittee: I am Charles W. Rau, Vice President - Taxes for MCI Communications Corporation. I am here today, in my capacity as the Chair of Tax Executives Institute's (TEI's) Task Force on Penalties, to present the Institute's views on H.R. 2528, the Improved Penalty Administration and Compliance Tax Act. I am accompanied by the Institute's Tax Counsel, Timothy McCormally, and together we will endeavor to answer any questions you might have about TEI's position on this very important subject.
I. Introductory Comments
Mr. Chairman, TEI is the principal association of corporate tax executives in North America. Our members have a little different perspective from some of the other organizations here today. The difference is this: TEI members are not tax advisers or return prepares; they are employed directly by corporations to manage their tax affairs. Thus, although we share the same goals and the same commitment to professionalism as the ABA,AICPA, and other associations of professional tax practitioners, the penalty issue hits a little closer to home. Our members are the ones that must struggle, on a day-to-day basis, to contend with an extremely complicated tax system - those who must discern what the tax law is and to institute practices and procedures to ensure compliance with it. It is our members who, in those cases where penalties are asserted, must face our senior management and explain why at times - despite our best professional efforts - a penalty is being asserted.
As an organization that has been involved in this issue from the outset - which testified before the Subcommittee on penalty reform more than a year ago and which you permitted to actively participate in the Subcommittee's very worthwhile roundtable discussions - TEI is extremely pleased with the introduction of H.R. 2528. We agree with the Chairman that the bill sets forth a credible framework for obtaining true reform of the tax law's penalty provisions. We further agree that a consensus on the major issues posed by penalty reform is clearly within reach. We commend the Chairman, the other members of the Subcommittee, and the staff for their efforts to date: the bill represents a definite improvement over current law and, although we urge the Subcommittee to consider some modifications and clarifications, we firmly believe H.R. 2528 represents a long and much needed step forward.
Mr. Chairman, before turning to our specific comments on H.R. 2528, I wish to note for the record that TEI filed detailed comments on penalty reform with the Subcommittee on May 24. (Those comments were reprinted in the May-June issue of TEI News.) Those comments set forth our specific recommendations for penalty reform. We are extremely pleased that certain of our recommendations have been incorporated into H.R. 2528. I ask that those comments be associated with the record for this hearing, and affirm our continued willingness to respond to any questions - from members of the Subcommittee or the staff - about our specific recommendations. Finally, I ask that, given the short time period between the introduction of H.R. 2528 and this hearing, the Institute be allowed, if necessary, to supplement our statement today with further written comments.
A. General Comments. Mr. Chairman, section 102 of the bill contains proposed amendments to the penalty provisions relating to the document and information reporting requirements of the Internal Revenue Code. Because of the retention of a reasonable cause exception in respect of penalty assertions, the introduction of a de minimis exception, and the addition of a time-sensitivity concept, TEI believes the proposed changes are generally excellent.
We say this, moreover, even though the bill would increase some of the maximum penalties that can be asserted against taxpayers. We feel compelled to comment, however, on the dramatic increase proposed in respect of the penalty to provide correct payee statements. Under the bill (proposed new section 6722(a)), a standardized penalty of $50 will be imposed in respect of a failure to provide a correct payee statement to a taxpayer; with respect to certain failures, such a penalty will represent a 1,000 percent increase from the penalty under current law. Although the establishment of a uniform penalty in respect of all such failures is desirable, we must question whether such an exponential increase is necessary.
B. Time Sensitivity and De Minimis Exception. Any concerns TEI has about the level of the proposed information reporting penalties (and the new, higher maximums) are greatly assuaged by the introduction of time sensitivity into the calculation of the penalty and the inclusion of a de minimis exception. By structuring the penalty under proposed new section 6721, the bill properly places the emphasis not on penalizing inadvertent or short-term failures to provide information returns but rather on obtaining the information necessary to ensure the payee's compliance with the income tax laws.
We note, however, that the penalty in respect of incorrect payee statements does not in its current form feature a time-sensitivity provision. Although recognizing that the August 1 date contained in proposed new section 6721(b)(2) would need to be adjusted to reflect the fact that payees must generally file their income tax returns by April 15, we recommend that the penalty for failing to provide correct payee statements be coordinated with the time-sensitivity provision of the penalty for failing to provide correct information returns. We also recommend that a de minimis exception, such as that set forth in proposed new section 6721(c), be made applicable in respect of failures to furnish correct payee statements.(1)
Similarly, we believe that closer coordination between the proposed failure-to-file-correct-information-returns penalty and proposed new section 6723 (relating to the failure to comply with other information reporting requirements) would be beneficial. Specifically, we believe that the inclusion of a time-sensitivity provision would encourage taxpayers to correct errors or otherwise satisfy the statutory requirements even after the due date (perhaps when inadvertent errors or failures are discovered); thus, the information necessary to ensure compliance would "enter the system." A de minimis exception also seems appropriate in respect of proposed new section 6723, and we recommend that such an exception be added to the bill.
Finally, we note that certain failures (e.g., the failure to include a correct taxpayer identification number) might give rise to the assertion of a penalty under both proposed new section 6721 and proposed new section 6723. We recommend that the committee report on the bill make it clear whether this is the case; if it is not, the bill could simply provide that, where a failure might give rise to a penalty under both provisions, only the proposed new section 6721 penalty would be asserted. Such a provision would not only eliminate the possibility of "stacking" but would also ensure that the potential overlap of the two penalties will not deprive taxpayers of the benefit of proposed new section 6721's time sensitivity.
C. Reasonable Cause Exception. Proposed new section 6724(a) provides that no penalty will be imposed where a failure to comply with information reporting requirements is due to reasonable cause and not to willful neglect. As previously stated, TEI applauds the inclusion of the reasonable cause exception and believes its inclusion in the bill, coupled with clarifying legislative history, will go a long way toward ensuring that information reporting penalties are asserted only where appropriate.(2)
TEI recommends that the committee report on the bill confirm that the purpose of the reasonable cause exception is to recognize that inadvertent errors may occur even where the taxpayer exercises reasonable care. Specifically, we believe an example could usefully be included in the committee report, confirming that reasonable cause exists where -
* the taxpayer establishes reasonable business procedures to ensure compliance with his obligation to file information returns, and
* the taxpayer makes a good faith effort to comply with those procedures.
This proposed clarification of the reasonable cause exception would operate to limit the imposition of penalties where taxpayers strive in good faith, but nevertheless fail, to fulfill their information-reporting obligations. We believe that the suggested language represents a reasonable extension of the statement in the summary explanation of the bill that no penalty should be imposed where "significant mitigating factors" are present.
III. Accuracy Penalties
A. General Comments. The genesis of the current efforts to reform the Internal Revenue Code's penalty provisions may rightly be said to be the accuracy penalties. Certainly to TEI's members, the accuracy penalties (and, in particular, section 6661) have been the most contentious.
TEI continues to question whether it is appropriate to assert a penalty against taxpayers in the absence of their negligent or fraudulent conduct. We believe the government has an obligation to assist taxpayers in determining what their tax liability is and, quite bluntly, an obligation to recognize that - best efforts not-withstanding - inadvertent errors are made, both by government and by taxpayers.
TEI is pleased that H.R. 2528 recognizes the existence of obligations on the part of not only taxpayers and tax advisers (including return preparers) but also tax administrators. We believe the bill makes helpful and important strides in recognizing the government's responsibility to define the scope of a taxpayer's obligations and to specify those areas where a penalty may be imposed for behavior less culpable than negligent behavior. Thus, we believe the bill promises to inject a fuller measure of balance into how the accuracy penalties are structured and administered.
In the comments that follow, we set forth our specific comments on section 201 of the bill, which contains proposed revisions to the Code's accuracy penalties. Preliminarily, we wish to underscore our belief that - without regard to the need or desirability of further refining the bill - H.R. 2528 represents a marked improvement over current law.
B. Coordinated Nature of the Accuracy Penalties. By including all the Code's accuracy penalties (with the exception of the fraud penalty) within a single, coordinated section of the Internal REvenue Code, the bill promises to eliminate the "stacking" of penalties. TEI endorses this result, and we commend the Subcommittee for its proposed coordination of the accuracy penalties, which will ensure that only the most appropriate penalty will be imposed. We also support the adoption of uniform criteria in respect of the waiver of the penalty (i.e., under the reasonable cause exception). (The reasonable cause exception is discussed in greater detail in part III.G.)
C. Targeted Nature of Accuracy Penalties. TEI is extremely pleased that, under proposed new section 6662, the Code's accuracy penalties will only be based on the amount of any underpayment giving rise to the penalty assertion (rather than to the entire underpayment). The proposed language represents a change from current law computation of the negligence penalty, which we heartily endorse.
D. Penalty Rate. TEI also endorses the bill's proposed reduction of penalty for substantial understatements of tax from 25 to 20 percent. This specific change, coupled with the Subcommittee's affirmation of the principle that penalties should not be enacted (or asserted) simply to raise revenue, is most welcomed. We also believe that the adoption of a uniform rate in respect of all the accuracy penalties (other than fraud) is appropriate, and in recognition of the change in the base upon which the negligence penalty is levied, we do not oppose an increase in the rate of that penalty.
E. Substantial Authority Test
1. Definition of "Authority". The Subcommittee has proposed very helpful changes in respect of the substantial authority provision of the penalty for substantial understatements of tax. Specifically, we are pleased that the summary explanation of the bill provides that the definition of authority should be expanded from that set forth in current Treasury regulations. The inclusion in this list of authorities of the Joint Committee's general explanations of tax legislation ("Blue Books"), proposed regulations, private letter rulings, and the other IRS documents set forth in the summary explanation will be beneficial - not only to taxpayers seeking to avert the assertion of a penalty but also to tax administrators striving to establish and confirm the even-handed nature of the tax system.
With respect to definition of "authority," we recomend that the committee report on the bill further provide that the following be added to the list of authorities that are to be taken into account in determining whether substantial authority exists:
* Pertinent statements of the Secretary of the Treasury or his delegate before Congress.
* Relevant colloquies between members of Congress on the floor of the House and the Senate, as well as statements by the sponsor of a committee or floor amendment.
Although these "authorities" (indicia of legislative intent) may not prove dispositive of a substantive tax law issue, we believe they should be taken into account in weighing whether a penalty should be asserted against a taxpayer who may have no other authority to rely on at the time the tax return is filed.(3)
2. Definition of "Substantial". In light of the recent recommendation of the Internal Revenue Service's Executive Task Force on Penalties (contained in its report of February 21, 1989) that the definition of "substantial" in the substantial authority test be changed, TEI recommends that the Subcommittee confirm that the current law definition should continue to have vitality. In this regard, we note that the IRS Task Force suggested in its February 21 report that the substantial authority standard be significantly increased to one approaching a 45-percent or higher probability of success.
TEI believes that, in order to prevent any confusion or misunderstanding, the Subcommittee should specifically address the appropriate definition of "substantial" for purposes of the substantial authority test. In this regard, we note that the Conference Report on the Tax Equity and Fiscal Responsibility Act of 1982 contains the following statement concerning the substantial authority standard:
The conferees believe that
such a standard should be less
stringent than a "more likely
than not" standard and more
stringent than a "reasonable
basis" standard. (H.R. Rep.
No. 97-760, 97th Cong., 2d
Sess. 575 (1982).)
We believe that the current law definition of substantial authority - as set forth in Treas. Reg. (section) 1.6661-3(a)(2) - is consistent with legislative intent as expressed in the Conference Report. It is also consistent with Congress's purpose in enacting the substantial understatement penalty:
The conferees did not adopt an
absolute standard that a taxpayer
may take a position on a
return only if, in fact, the position
reflects the correct treatment
of the item because, in
some circumstances, tax advisors
may be unable to reach so
definitive a conclusion.
Rather, the conferees adopted
a more flexible standard under
which the courts may assure
that taxpayers who take
highly aggressive filing positions
are penalized while those
who endeavor in good faith to
fairly self-assess are not penalized.
(H.R. Rep. No. 97-760,
TEI recommends that the committee report confirm that the current law definition of "substantial" authority will be retained, thereby rejecting the stricter standard proposed by the IRS Task Force's February 21 Report. Indeed, in light of the "realistic possibility of being sustained on its merits" standard set forth in proposed new section 6694(a)(1) (in respect of return preparer penalties), it may be appropriate to consider whether that revised standard should also apply to taxpayers under the substantial understatement penalty set forth in proposed new section 6662(b)(2).(4)
F. Secretarial List of Issues
1. General Comments. Under proposed new section 6662(d)(2)(D), the Secretary of the Treasury is to prescribe (not less than annually) a list of issues of positions affecting a significant number of taxpayers for which the Secretary believes there is not substantial authority. According to the summary explanation of the bill, this list is intended to assist taxpayers in determining whether a position should be disclosed in order to avoid the substantial understatement penalty.
TEI believes the required publication of a list of positions in respect of which the IRS does not believe there is substantial authority is consistent with the notion that the government has an affirmative obligation to assist taxpayers in ensuring compliance with the tax laws. We recommend, however, that the list be published - not in the Federal Register (to which most taxpayers do not have routine access) - but rather in the instructions to the year's tax returns (or schedules). This would make it more likely that taxpayers would be in a position to use the list for its intended purpose: determining whether or not particular positions should be disclosed.
2. Taxpayer's Ability to Rely on Secretarial List. As discussed more fully in TEI's May 24 comments (pages 11-14), we believe that absent knowledge of a specific tax law issue, a taxpayer should be subject to the substantial understatement penalty only for failing to disclose issues contained in the IRS's published list. This is particularly appropriate since the negligence and substantial understatement penalties are identical under the bill (i.e., no greater penalty would be imposed for negligent behavior than for conduct giving rise to the substantial understatement penalty).
Thus, TEI submits there is a need to ensure that the substantial understatement penalty will not be imposed for the failure to disclose an undiscovered tax law issue. We think the responsibility of the government to share the obligation of maintaining our self-assessment tax system justifies according taxpayers, absent negligence, the ability to rely on the IRS's published list.
G. Reasonable Cause Exception
1. General Comments. As previously stated, TEI applauds the Subcommittee's decision to provide standardized waiver criteria in respect of accuracy penalties and applauds the decision to structure proposed new section 6664(c)(1) to accord taxpayers a right to penalty relief where "it is shown that there was a reasonable cause for such portion [of the underpayment] and that the taxpayer acted in good faith with respect to such portion." Once again, we believe the Subcommittee rightfully concludes that penalties should not be asserted where the taxpayer strives in good faith to comply.
2. Clarification of What Constitutes Reasonable Cause. TEI urges the Subcommittee to confirm that, in determining whether a taxpayer is entitled to relief under the reasonable cause exception, due weight must be accorded to the complexity of the rules with which the taxpayer must grapple, as well as to the operational constraints under which taxpayers - striving in good faith to comply with the tax laws - must operate. In other words, we believe there should be some limit placed on taxpayers' obligation to discover all tax law issues that might be encompassed within their tax returns.
TEI believes it would be appropriate to limit all taxpayers' obligations to disclose only (i) tax law issues that the IRS has specifically listed for the year or (ii) tax law issues of which the taxpayer is aware. We submit that this is especially important for larger corporations whose returns might contain inadvertent factual errors, as well as a number of unidentified (and, as a practical matter, unidentifiable) tax law issues.(5)
Thus, we recommend that the committee report acknowledge that the reasonable cause and good faith standards can be met without requiring the taxpayer to discover all the tax law issues that may exist in respect of his return. Moreover, in determining whether the standards have been satisfied, the inquiry should focus on whether the taxpayer establishes reasonable business procedures to ensure compliance with his obligation and makes a good faith effort to comply with those procedures.
With particular regard to corporate taxpayers, we believe an evaluation of the taxpayer's good faith should be based on the actions (or inactions) of those corporate employees and outside advisers who have responsibility for the corporation's tax affairs. For example, no penalty should be imposed where the corporation establishes reasonable business procedures designed to ensure compliance with the tax laws and takes steps to ensure that those procedures are followed, but a non-tax responsible employee of the corporation fails to implement those procedures. Such a clarification of the reasonable cause exception would alleviate taxpayer concerns that they may be subject to penalties notwithstanding their best (good faith) efforts to comply. It would also be consistent with statements of then-Commissioner Roscoe L. Egger, Jr. (shortly after the enactment of section 6661) that "the corporate tax department must be able to rely on the company's internal controls.(6)
3. Applicability of Reasonable Cause Exception in Respect of Certain Charitable Contribution Deductions. Under proposed new section 6664(c)(2), the reasonable cause exception will not be available in the case of the assertion of the substantial overvaluation penalty in respect of charitable deduction property unless the claimed value of the property was based on a qualified appraisal by a qualified appraiser. We note, however, that section 170 and the applicable substantiation regulations do not require the taxpayer to obtain a qualified appraisal in all instances. Indeed, on September 16, 1988, the IRS issued an information release (IR-88-137) providing that final regulations under section 170 would exempt "certain corporations from obtaining appraisals for gifts of inventory for the care of the ill, the needy, or infants or for research."(7)
Where a corporation fully complies with the provisions of the Internal Revenue Code relating to the substantiation of its deduction of charitable contribution property, TEI believes the assertion of a valuation overstatement penalty is inappropriate. Thus, we recommend that the Subcommittee clarify that a taxpayer fully abiding by the regulations under section 170 will not be precluded from relief under the reasonable cause exception where those regulations do not require the taxpayer to obtain a "qualified appraisal" by a "qualified appraiser."(8)
4. Taxpayer Challenge to IRS Rules or Regulations: Effect of Disclosure on Assertion of Negligence Penalty. Under the bill, the negligence penalty is to be asserted for the "disregard of rules or regulations." Thus, a taxpayer who believes an IRS ruling or regulation is erroneous and wishes to challenge ("disregard") that ruling potentially faces a negligence penalty. Although the proposed statutory language does not represent a change from current law, we believe the possible assertion of a penalty in such a case would be improper where a taxpayer expressly discloses his position on a tax return.
TEI believes that taxpayers who believe in good faith that an IRS ruling or regulation is erroneous and decide to challenge that ruling or regulation as inconsistent with the applicable statute or with case law should not be subject to a penalty where they specifically disclose their position. Consequently, we recommend that the Subcommittee confirm that the reasonable cause exception will apply in such cases.
IV. Failure-to-Deposit Penalties
Section 402 of the bill would amend section 6656 of the Code relating to penalty for failing to make timely deposit of tax. TEI believes that the changes proposed by the Subcommittee are, on the whole, excellent. First, we believe that the inclusion of a time-sensitivity provision will further the goal of encouraging compliance. Secondly, the retention of a reasonable cause exception ensures that taxpayers who endeavor in good faith to comply will not be automatically subject to a penalty where, despite the taxpayers' best efforts, a failure occurs.
In conclusion, TEI again suggests that the committee report include an example illustrating that a penalty will not be asserted where the taxpayer adopts reasonable business practices designed to ensure compliance with the tax law and makes a good faith effort to follow those practices.
V. Corporate Estimated
H.R. 2528 does not address the area of what we call "non-penalty penalties" - substantive provisions of the tax law that require a taxpayer to suffer an unwarranted economic loss in order to avoid a formal penalty. Perhaps the prime example of such a provision is the overpayment of estimated taxes effectively required to be made by larger corporations - those with taxable income of more than $1 million in any of the preceding three years - in order to avoid a "real" penalty under section 6655. This is due to the inability of such corporations to make estimated tax payments on the basis of their prior year's tax liability.
In our May 24 statement on civil penalty reform (pages 25-28), we discuss the operation of the Code's estimated tax provisions and demonstrate how the provisions operate as a penalty. We also set forth several concrete alternatives that could be adopted to eliminate, or at least temper, this particularly odious and unfair "non-penalty penalty."
TEI recognizes the desirability of limiting the scope of the Subcommittee's bill. We nevertheless recommend that consideration be given to including corporate estimated tax payment relief within the ambit of H.R. 2528. In this regard, we invite questions concerning our proposals and would welcome the opportunity to work with the Subcommittee and the staff in developing appropriate amendatory language.
TEI applauds the Subcommittee's decision to develop a set of administrative recommendations to accompany its statutory penalty reform package. We are particularly pleased with the statement (Administrative Recommendation A.8.) that -
In the application of penalties,
the IRS should make a correct
substantive decision in the
first instance rather than mechanically
with the idea that they will be
TEI is pleased that the Subcommittee has concluded that the procedural handling - and timing - of a penalty determination may be as important as arriving at a substantively correct penalty determination. We submit that the question of where in the process the penalty assertion is reviewed takes on added significance in respect of larger corporations in light of the complexity and the number of issues that commonly arise in such audits.
In our May 24 statement, we explore at length the IRS's prior use of Penalty Screening Committees (PSCs) in the various IRS districts. We recommend (at pages 18-21) that the structure of and operating procedures in respect of PSCs be revised in an effort to resolve penalty assertions at the audit level. We also state that the adoption of such a procedure could well obviate the need for the penalty issue to be considered at the Appeals level - where generally a quid pro quo attitude prevails and the taxpayer may be at a substantial negotiating disadvantage.(9)
The recommendations concerning PSCs set forth in our May 24 statement are designed to minimize confusion and facilitate the uniform application of the Internal Revenue Code's penalty provisions. Thus, they are fully in accord with the purposes and intent of H.R. 2528 and the Subcommittee's administrative recommendations. Consequently, we urge the Subcommittee to consider including a specific reference to the operation of Penalty Screening Committees in its administrative recommendations.
Mr. Chairman, Tax Executives Institute appreciates the opportunity to present our views on H.R. 2528. In summary, we believe that the bill represents a vast improvement over current law. We look forward to working with the Subcommittee in supporting and hopefully refining the legislation and would be pleased to respond to any questions you or other members of the Subcommittee might have.
(1) Because of the time constraints placed on the preparation of this statement, TEI declines at this time to comment on the appropriateness of the particular de minimis exception set forth in the bill. We applaud the decision to include a de minimis rule in H.R. 2528 but are unable to currently state whether refinements are necessary to ensure the effective operation of the exception.
(2) In this regard, we believe that the proper interpretation and application of the reasonable cause exception will mitigate the concerns expressed in part II.C., relating the need to better coordinate the time-sensitivity provision and de minimis exceptions of the information-reporting penalties.
(3) We suggest it would also be useful if the Subcommittee confirmed that, in respect of many issues (in particular, those implicating recently enacted legislation), there may be no clear authority one way or another. Thus, the regulations should continue to provide that "[t]here may be substantial authority for more than one position with respect to the same item" (Treas. Reg. (section) 1.6661-3(b)(1)), and that "a taxpayer may have substantial authority for a position that is supported only by a well-reasoned construction of the applicable statutory provision." (Treas. Reg. (section) 1.6661-3(b)(3).)
(4) TEI believes that the application of the same standard to both taxpayers and the advisers (or return preparers) on whom they rely would be consistent with the goal of recognizing the mutual obligation to our tax system that should be shared by taxpayers, their advisers, and the government.
(5) The tax return of a large company will not infrequently be several thousand pages in length and will encompass literally millions of transactions involving myriad subsidiaries. In completing the return, the corporation's tax staff must of necessity rely on the financial books and records of the company (which are generally reviewed by independent auditors and, in respect of publicly traded companies, prepared pursuant to the Securities Exchange Act of 1934 and the Foreign Corrupt Practices Act). Additionally, tax law issues frequently arise during the course of audits that involve (i) the taxpayer's continuing to follow (absent a change in the applicable statutory provision) long-standing practices; (ii) situations where the revenue agents raise legal issues that have not been prviously raised (either with the particular taxpayers or with other taxpayers); (iii) the promulgation of new Treasury or IRS positions subsequent to the filing of the tax return; or (iv) inadvertent factual errors that lead to the taking of erroneous tax law positions on the tax return.
(6) The quotation is taken from the minutes of an April 13, 1983, liaison meeting between TEI and senior IRS officials (including Commissioner Egger). (The minutes were approved by the IRS before they were released.) The minutes also quote the Commissioner as stating that "[i]f a taxpayer follows its normal procedures but there is a `glitch,' the penalty should not be imposed."
(7) Although a qualified appraisal will not be required under the (still-not-released) final regulations, affected taxpayers will be required to include summary information in their annual returns.
(8) We note that proposed new section 6664(c)(3)(C) provides that the term "qualified appraisal" means any appraisal meeting the requirements of the section 170(a)(1) regulations; under the bill, however, it is unclear whether the reasonable cause exception will be available where the person making such an appraisal is not a "qualified appraiser."
(9) In this regard, we are also pleased with Administrative Recommendation C.3, which provides that the IRS "should instruct its employees that they cannot threaten the use of preparer penalties during an examination, appeals conference, or other proceeding involving a tax adviser." We recommend that the Subcommittee clarify that threats to assert a penalty unless there is a taxpayer concession on the substantive issue are generally inappropriate (without regard to whether the taxpayer is represented by an outside adviser).
|Printer friendly Cite/link Email Feedback|
|Title Annotation:||written statement of testimony presented by Charles W. Rau for Tax Executives Institute before the House Committee on Ways and Means|
|Date:||Jul 1, 1989|
|Previous Article:||Minutes of 1989 TEI-IRS liaison meeting: April 26, 1989.|
|Next Article:||The "secretarial list" requirement of pending penalty legislation, June 14, 1989.|