The IRS announced in an email to practitioners that it is pushing back the effective date for its new information document request (IDR) procedures to March 3 (e-News for Tax Professionals 2014-6 (Feb. 7, 2014)). The new procedures had been scheduled to start Jan. 2.
The new IDR procedures were announced in a directive issued last November by the IRS’s Large Business & International (LB&I) Division (LB&I-04-1113-009). They are designed to shorten the time taxpayers are given to respond to an IDR and narrow the focus of IDRs. The directive announcing the new procedures provides a 13-step process for IRS examiners to use when issuing IDRs. The directive also outlines three mandatory enforcement steps if a taxpayer does not respond or provides an inadequate response: (1) a delinquency notice, (2) a presummons letter, and (3) a summons.
The IRS email postponing the new procedures until March 3 does not explain the reason for the delay, other than to say that is “to provide the clarification that is necessary to ensure that the procedures governing IDR issuance and enforcement are easily and clearly understood.”
—Alistair M. Nevius (
) is the JofA’s editor-in-chief, tax.