Comment on FR Doc # E8-21158

Document ID: IRS-2008-0097-0003
Document Type: Public Submission
Agency: Internal Revenue Service
Received Date: September 29 2008, at 08:02 PM Eastern Daylight Time
Date Posted: September 30 2008, at 12:00 AM Eastern Standard Time
Comment Start Date: September 11 2008, at 12:00 AM Eastern Standard Time
Comment Due Date: December 10 2008, at 11:59 PM Eastern Standard Time
Tracking Number: 8072da71
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IRS Reg-160868-04 (RIN 1545-BF61) appears to mix references to IRC Section 6011, which deals mostly with electronic filing and general requirements for filing, and Treasury Regulation 1.6011, which deals with requirements for reporting tax shelters and specific classes of reportable sheltering transactions, which appears to be the intended reference. As written, I was very confused - I believe the IRC Section 6011 references should be changed to Reg 1.6011, or reference the actual IRC section(s) such as IRC 6707 that deal with reportable transactions and shelters, not the most generic reporting requirements section (IRC 6011). As written, would potentially impose $10,000 to $100,000 penalties on individuals for even unintentionally omitting ANY information on ANY type of return, regardless of whether it involved a reportable transaction or tax shelter, which is the obvious intended target of this regulation.

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Comment on FR Doc # E8-21158
Public Submission    Posted: 09/30/2008     ID: IRS-2008-0097-0003

Dec 10,2008 11:59 PM ET