December 8, 2009
CC: PA: LPD: PR (REG-112756-09)
Room 5203
Internal Revenue Service
P.O. Box 7604
Ben Franklin Station
Washington DC 20044
I am concerned about having a high level of review before the IRS initiates a church inquiry, because the section 7611 regs say the reasonableness of a reasonable belief determination is not susceptible to judicial review. This could result in an examination project focused on a particular religious denomination, or on randomly selected churches, and the decision could never be challenged if the person approving it is also the same one who approves church inquiries.
The proposed regulations could result in excessive government entanglement in the affairs of churches. They are also unlikely to resolve ongoing challenges to church inquiries.
I recommend that the person authorized to initiate a church inquiry be the Deputy Commissioner, Services and Enforcement.
Respectfully submitted,
Todd Fisher, CPA
15215 Endeavor Drive
Noblesville IN 46060
Comment on FR Doc # E9-27773
This is comment on Proposed Rule
Amendments to the Regulations Regarding Questions and Answers Relating to Church Tax Inquiries and Examinations; Hearing
View Comment
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