Home · Online Publications · The Tax Adviser · Tax Adviser Index 1990-1999 · Broad Categories · Procedure & Administration Search Feedback

Procedure & Administration

See also Internal Revenue Service and Returns.

Accountant-client privilege. 95:726; 96:154; 98:306, 517, 676; 99:772.
Accounting firm pretransaction memoranda. 96:357.
Accuracy-related penalty. 94:179, 315; 95:413; 97:772.
Adequate disclosure. 90:418; 91:274; 92:326, 375.
for Sec. 6662. 94:454.
guidelines. 96:124; 98:196; 99:277.
Adjustments
effect of settlement agreement on. 95:251.
Administration's
corporate tax shelter proposals. 99:346.
fiscal-year 1998 budget. 97:473.
Administrative costs. 93:133.
Adoption tax identification numbers. 98:5.
Advance Pricing Agreement Program. 95:445.
AFRs. 98:307.
AICPA-IRS meeting. 97:111.
AICPA-JCT meeting. 97:112.
AICPA's perspective. 97:320.
Alternative dispute resolution. 95:219; 96:281; 99:734.
APA procedures for small businesses. 98:467.
Appeals protests
written rebuttals. 94:28.
Assessment amount. 97:188.
Assessment period
effect of S shareholder's personal extension. 92:557; 93:267.
grantor trust beneficiaries. 92:840.
partner's. 93:471.
S items on shareholder's return. 92:414.
tax shelter promotions. 93:135.
Attorney-client privilege
CPA's work for corporate attorney. 95:34.
Attorney
fee reimbursements. 98:672.
fees, reporting requirements. 99:736.
Attorneys and CPAs as enrolled agents. 95:186.
Audit odds. 98:205 (chart); 99:373.
Authority on amended returns. 96:276.
Automatic extensions. 94:148.
Back pay awards. 94:645.
Backup withholding
regulations. 96:153.
retirement plan trusts. 99:708.
Bank accounts under levy. 93:266.
Bankruptcy
allocations of tax payments. 91:383.
ascertaining taxable estate. 95:529.
Chapter 7 vs. Chapter 13. 93:513.
procedures. 98:736.
Burden of proof. 99:770.
Carryback waiver election. 92:128.
Cash reporting. 90:591; 91:569; 92:64.
Change of address. 90:386.
Check-the-box regs. 97:296, 749.
Circular 230
final regulations. 95:647; 711.
proposed regulations. 93:191.
"scenarios." 96:6, 46; 97:260, 364, 748.
Classification
liberalized worker rules. 97:17.
of entity election. 95:313; 96:478.
of newspaper delivery people. 95:424.
of part-time law clerk. 97:56.
of workers in entertainment industry. 95:409.
settlement program. 96:316, 358.
Closed tax year. 98:464.
Closing agreements. 98:391.
Collection financial standards posted on Internet. 97:608.
Collection limits. 99:317.
Community property state, spousal refund claims. 98:345.
Computerized record retention rules. 92:441.
Condominium association
filing options. 91:577.
Comprehensive tax reform proposals. 95:356.
Continuing levy notice. 95:360.
Corporate employment taxes. 98:517.
Corporate quick refund. 93:224.
Corporate return signature authority. 99:487.
Corporate tax shelters. 97:693.
Correcting depreciation errors. 96:540.
Cost of Federal tax administration. 97:473.
Credit card tax payments. 97:609; 99:72.
Crediting IRS-employee embezzled taxpayer accounts. 99:5.
Customs Modernization Act. 97:697.
Deferring directors' fees. 92:30; 99:400.
Designated delivery services. 96:720; 97:196, 261, 392; 98:58.
Disaster relief. 93:614.
Disclosure statements. 97:186.
processing of returns containing. 96:415.
Dishonored check penalties. 97:808.
Early referrals to Appeals. 99:709.
Economic reality audits. 95:752.
EFT
penalty waiver. 99:362.
prop. regs. 99:285.
use requirement. 95:701; 96:541; 97:197, 230, 661; 99:4.
EIC due diligence. 98:192.
Elections. 94:576.
Electronic
filing. 96:6, 69; 97:789; 98:285, 761.
imaging. 98:157.
record retention rules. 98:495.
Employee fringe benefit plans
filing requirements. 90:288.
Employment taxes
classifications. 98:656.
deposits. 91:195; 94:247.
employee status
        apartment manager. 90:129.
employee suit for failure to withhold. 99:138.
interest-free adjustments. 92:511.
liabilities. 98:544, 576.
procedures for disputing classification. 98:758.
reporting in business acquisitions. 97:696.
students' exemption. 93:748.
Estimated tax
automatic extension. 91:101.
corporate. 90:222; 92:157.
corporations with no tax. 92:711.
new rules. 92:156, 203, 460.
payments. 93:769.
penalty avoidance. 96:507.
private foundations. 92:726.
special rules. 92:341.
use of rollovers to avoid problems. 91:515.
Examinations
time and place. 93:398.
Exceptions to physical delivery rule. 92:772.
Expatriation statements. 96:676; 97:197.
Expedited routing forms. 93:29.
Extensions
for elections. 93:534.
for filing gift tax returns. 94:298.
payment sent with request. 98:510.
reasonable estimate requirement. 96:612.
reliance on agent to file. 97:598, 629, 662.
remittance sent with request. 96:585.
Fact-of-filing requests. 94:452.
Failure to deposit penalty. 98:306.
Failure to file penalty. 97:420.
financial hardship. 99:22.
Failure to waive penalty. 95:468.
FICA
on employee tips. 99:706.
student exemption. 98:228.
taxes on plan contributions by salary reduction of state employees. 98:873.
taxes on tip income. 95:183; 96:355.
Fifth amendment issues. 99:677.
Financial status audit techniques. 96:110, 218.
Filing statistics. 99:208.
Foreclosure on taxpayer's property and spousal
interest. 95:703.
Form 872 revisions. 97:455.
Form 1040-V payment voucher. 96:132.
Form 5300 filing as basis for Sec. 6701 penalties. 96:517.
Form 8275 disclosure. 96:10.
Form 8866. 99:208.
Fraudulent return criminal penalty. 98:240.
Fringe benefit reporting. 90:57.
GAO report on return selection process. 99:208.
Gift tax return disclosure. 98:284.
Golden parachute sanctions. 96:413.
Historical individual income tax rates. 97:766.
Hot interest. 98:147, 158; 99:161.
Household workers
filing requirements for. 95:148.
payroll tax rules. 95:530.
Imaging systems for books and records retention. 96:672.
Improper IRS conduct. 97:174.
Improper practitioner conduct. 96:46.
Income reconstruction. 92:536.
Independent contractor vs. employee
audit strategy. 98:328.
avoiding IRS reclassification. 96:102.
burden of proof. 97:642.
determining status. 90:226, 342; 91:225.
home care workers. 92:592.
independent dealership salesmen. 96:650.
IRS compliance check. 95:512.
IRS guidance. 96:196.
safe harbor
        different industry. 90:457.
        proposal. 95:509.
        Section 350. 92:816.
state and local government employers. 92:374.
Individual Taxpayer Identification Number. 95:700; 96:397; 97:275.
Informal claims. 95:247.
Information reporting requirements. 97:421; 99:485.
attorneys' cash transactions. 94:339; 752.
attorneys paying experts. 98:395.
brokers. 92:323.
changes in corporate control or capital structure. 90:591.
frequent flier programs. 93:818.
gifts from foreign persons or estates, 98:754.
mortgage points. 91:58.
outbound transfers. 97:151.
penalties. 90:524; 91:271; 92:127; 94:222.
post-TRA'97. 98:226.
return requirements. 90:698.
Information return filers. 91:380.
Innocent spouse. 91:479; 93:253; 96:524; 97:663; 98:276, 708.
Installment agreements. 93:194, 354; 95:117; 97:608.
Installment payments. 98:674.
of retroactive tax increase. 94:648.
Interest abatement. 99:234, 688, 816.
Interest netting
rules. 99:94; 401, 773.
SOL. 99:23.
Interest on
overpayments. 92:694.
penalties. 94:611.
tentative refunds. 91:29.
underpayment, elimination by FTC carryback. 96:671.
Invalid return. 99:689, 773, 869.
IRS
budget cuts. 96:699.
Commissioner's restructuring plan. 98:140, 517.
field service advice memoranda. 96:356.
forms and publications (box). 98:5.
help hotline. 99:72.
informal technical advice. 92:96.
levies. 91:835.
mission statement. 98:737.
new headquarters locations. 99:144.
new structure. 99:592.
Practitioner Hotline Phone Numbers (chart). 96:133; 97:197.
RRA '98 taxpayer rights. 98:757.
Joint Committee on Taxation penalty study. 99:616.
Joint returns
substitute return procedures. 91:585.
Leased employees. 94:414.
Levy
effect of honoring. 93:198.
notice of continuing levy. 95:360.
TRA '97 changes. 97:767.
Lien on personal property. 93:398.
Line Item Veto Act. 97:261, 748.
Loan origination costs
change in treatment. 93:379.
Malpractice
running of statute of limitations. 97:62.
Manual signature requirement. 93:398.
Market Segment Understanding Program. 95:445.
Medicaid transfers criminal penalty. 98:17.
Medicare coverage data bank. 94:753.
Miscellaneous regulations. 96:68.
Nanny tax. 96:85.
1996 fiscal-year receipts. (chart). 96:260.
New tax forms (box). 99:145.
Nonjudicial real estate sales. 95:445.
No ruling policy. 91:234.
Obsolete regulations, procedures, rulings. 95:700.
Offers in compromise. 92:619, 631, 661; 94:771; 97:454, 608; 98:76; 99:284, 617, 738.
Offsetting in multiyear audits. 98:158.
100% penalty. 92:608; 97:608; 98:95.
Outbound transfers
penalty for failing to report. 97:294.
Overpayment of tax
crediting
        against estimated tax. 98:159.
        against subsequent year's deficiency. 98:58.
definition. 97:680.
Paperless automatic extensions. 95:279.
Partial disallowance of penalties. 93:357.
Partial payments. 90:158.
Partnership item SOL. 90:286.
Payments to attorneys for clients. 99:456.
Payroll reporting. 97:554, 630.
Penalties for failure to file agency authorization. 96:11.
Penalty rules. 94:610.
Percent of income taxes paid by income group (chart). 97:261.
Powers of attorney. 91:475.
and mental incompetence. 98:305.
Practitioner standards. 93:22.
Preparer penalties. 90:345; 91:272; 92:208, 331, 464; 95:67; 96:260.
Protective refund claims. 93:24.
QSSS employment taxes. 99:200.
Realistic possibility standard. 91:279.
Reasonable basis disclosure standard. 94:341; 97:496.
Reasonable cause for abating penalties. 93:291.
Reckless disregard as willfulness. 96:448.
Record retention, limiting. 98:462.
Refund
adequacy of claim. 93:702.
claim SOL, equitable tolling. 97:196, 253, 662; 99:318, 372.
claim versus tentative carryback. 96:763.
crediting. 90:92.
filing of suit as providing sufficient notice. 96:648.
for delinquent filers. 96:188, 216.
large
        Joint Committee Review. 96:414.
period for nonfilers. 93:179.
spouse's child support obligations. 93:568.
start of period based on NOL carryback. 96:452.
unconstitutionally collected taxes. 94:364.
undeliverable. 98:5; 99:4.
Regulations projects. 98:808.
Reliance
on accountant's advice. 91:339; 99:440, 815.
on advice of others. 95:218.
on expert advice. 96:81.
Reporting back pay awards. 94:645.
Report of control or capital structure change. 91:33.
Required deposits of fiscal-year S corporations and partnerships. 95:274.
Required electronic FTDs. 95:32; 96:440, 635, 656; 97:48, 230, 336.
Responsible person. 90:390; 96:450; 97:736.
Return preparer
errors. 96:68.
identification number. 99:689, 739.
partnership's as partners'. 92:412, 626; 94:124.
Revised rules of practice before IRS. 95:266.
Sec. 6662
applicability to employment taxes. 98:760.
penalty relief. 99:93.
Sec. 6672
        liability for arranging financing agreement. 96:125.
        reckless disregard as willfulness. 96:448.
Sec. 6695(b) penalty. 98:440.
Sec. 7202. 97:740.
Self-employment planning. 96:703; 97:459.
Separate returns
high income married taxpayer. 92:102.
Settlement fund reporting. 96:197, 232.
Small Business Administration assistance. 99:373.
Social Security
benefit planning. 92:43.
records. 96:197.
Software, IRS summons disallowed. 98:756.
SOLs
and consistency doctrine. 95:85.
closed years. 91:445.
effect of filing wrong return. 93:331, 354.
exceptions. 97:491.
gift tax vs. estate tax. 91:838.
on malpractice claim. 97:62.
on refund claims, mitigation. 97:289.
on trust fund recovery assessments. 97:290.
preassessment remittance. 93:648.
refund claim by nonfilers. 95:62.
Sec. 183 special limitation period. 91:760.
Special-use valuation election period. 97:600.
SRTPs
ethical recognition issues. 97:654.
State enforceability. 96:501.
Stock transfers. 97:768.
Subsequently determined deficiency. 99:760, 870.
Substantial understatement penalty. 96:277; 99:20.
Supplemental assessment. 98:132.
TAM presubmission conferences. 97:326, 453.
Taxes as a percentage of household income (chart). 96:657.
Tax bite in the eight-hour day (chart). 97:5.
Tax freedom day (chart). 97:5; 99:209.
Taxes by type and level (chart). 99:5.
Taxing electronic transactions. 97:5.
Taxpayer appeals. 93:745.
Taxpayer assistance orders. 92:323.
Taxpayer Bill of Rights 2. 96:247, 524, 636; 97:426, 536.
Taxpayer Bill of Rights 3. 98:261.
Taxpayer Compliance Measurement Program. 95:377, 697.
Tax rates, effect of possible changes. 92:278.
Tax records, review of same records for different years. 94:775.
Tax shelter penalties
corporate tax shelters. 97:693.
assessed against partnership. 93:618.
Telephone number penalty relief. 96:593.
Third-party notices. 99:284.
Third-party summonses. 99:484.
Third-party trust fund liability. 95:59.
TIN matching program. 94:342.
Tips
credit for professional employer organizations. 97:631.
IRS employer-only assessments. 97:152.
rate determination program. 95:154; 96:479.
Trade or business, rendering fiduciary services. 91:411.
Transferee bound by transferor's closing agreement. 96:50.
Transferee liability. 90:769.
Transfer pricing
audits. 94:545.
"most current data" requirement. 96:11.
penalties. 94:417.
Treasury Inspector General. 99:145.
Treaty-based return positions. 90:591.
Unclaimed losses and credits
carryforward. 91:304.
Undeliverable refunds. 98:5.
Withholding
back-up. 90:730.
payroll tax penalties. 90:297.
third-party liability. 94:160; 95:59, 571.
Work-product privilege. 95:608.
Back
©1999 AICPA