Got a question for the Internal Revenue Service that needs answering? Why not ask your local stakeholder liaison? Who’s that? They are IRS employees who are attempting to establish a relationship with those representing small business and self-employed taxpayers. The liaisons provide very specific information about the policies, practices, and procedures followed by the IRS.Take for example the Issue Management Resolution System (IMRS), a stakeholder liaison initiative intended to capture, develop, resolve, and respond to significant national and local stakeholder issues. Under the program, practititioners’ notify IRS of concerns about IRS policies, practices, and procedures, and IRS researches the issues to bring about resolution.

Here are examples of issues recently resolved:

IMRS 06-0000340 – Form 2210, Underpayment of Estimated Tax by Individuals, Estates and Trusts
Issue:  Practitioners would like the option of filing more than one Form 2210 when e-filing.
Status:  ETA advises that the number of occurrences for Form 2210 will increase to two for tax year 2006. IMRS 06-0000328 – Direct Debit Payments
Issue:  Practitioner wants to know why the IRS cannot accept direct debit payments for interest and penalty with late filed e-file returns.
Status:  Currently IRS requirements limit the direct debit payment amount to the amount of tax owed on the tax form (not including interest and penalties). We will research this matter to determine if it is feasible to accept penalty and interest payments via EFT in Filing Season 2008.

IMRS 06-0000114 – Form 1098, Mortgage Interest Statement, Form 1099, Information Return for Calendar Year, and Form 5498, IRA Contribution Information
Issue:  Practitioners advised that they are unable to file downloaded copies of Forms 1098, 1099 and 5498. They are required to use special red forms when they file these forms. They incur additional costs when they obtain these special forms, and at times are unable to order a sufficient number. The IRS has developed a K-1 process that enables a tax professional to generate a K-1 that can be processed by machines. Is there a plan to implement a process for Forms 1098, 1099 and 5498?
Status:  K-1s can be scanned and processed because they go through a template matching process. There are over 500 different templates used to match the K-1s. While this process can be used for the 1099/1098 documents, it will have a significant cost implication, because up to 1,000 templates are associated with the documents. The Taxpayer Advocacy Panel is actively pursuing this issue, but the cost/implementation studies have not been completed. The IRS introduced the Filing Information Returns Electronically (F.I.R.E.) system in recent years to facilitate filing information returns for both large and small businesses. The F.I.R.E. system is available even if the taxpayer is required to file only one 1099. This may serve as a viable alternative until a final decision has been made on the template process. Please visit the electronic filing section of IRS.gov for more information and enrollment procedures for the F.I.R.E. system.

Here are some of issues recently raised by practitioners:

07-0000358 – Power of Attorney Forms
Issue:  Practitioner advises that on numerous occasions when faxing Form 2848, Power of Attorney, to the Centralized Authorization File (CAF) Unit, the fax number continually rings but the document never transmits.   06-0000348 – Copies of Returns
Issue:  Practitioners complain that when taxpayers are selected for examination, the revenue agents and tax compliance officers do not have access to complete copies of tax returns including attachments. The examiner will request a copy of the return from the taxpayer or his representative.  When the full return is disclosed to the examiner, often there is no change because the questionable items are fully explained on the complete return.

06-0000347 – Currency Transaction Reports
Issue:  CPA suggests depositors making deposits on behalf of an organization be given a copy of the CTR for their tax records in case of an audit.

Nice to see a positive IRS outreach program that is working to expeditiously deal with everyday tax practice concerns. If you have questions or concerns for the IRS, the telephone numbers for your local stakeholder liaison may be found at www.irs.gov/businesses/small/article/0,,id=153991,00.html and further details about IMRS are at www.irs.gov/businesses/small/article/0,,id=158507,00.html. I would appreciate if those who use or used IMRS would let me know your impression of the program, and if the IRS delivered on its promise.

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