Comment on FR Doc # 2010-22624

I like that the proposed rule could be a new tool in the IRS arsenal to streamline audits on large corporate taxpayers. I believe the new rule could revolutionize the audit process for taxpayers affected. Doug Shulman has said that 10 - 25% of audit time is spent identifying issues in returns. By requiring taxpayers to disclose uncertain tax positions, the IRS should be able to resolve issues earlier. It could be argued that the increased burden and cost on the affected taxpayers is disproportionate to the actual benefit to the IRS, but this argument ignores the fact that the resolution of one taxpayer's uncertainty has the potential to help all taxpayers who face the same issue. I hope this rule will promote efficiency and transparency in the tax system. I do wonder, however, if the IRS will keep records on the nature of uncertain tax positions disclosed by taxpayers to identify gaps in tax guidance. If, for instance, many taxpayers disclose UTPs resulting from one code section or regulation, it would seem a good chance for the IRS to identify the troublesome section/regulation and revise it.