IRS Initiates Early Resolution Program for LMSB Issues

The IRS and the Treasury Department have launched a pilot program designed to address issues that are common to large or midsize business taxpayers.

According to Larry Langdon, commissioner of the Large and Mid-Size Business (LMSB) Division, the aim of the industry issue resolution (IIR) program is to establish a consistent IRS position on industry issues, which will eliminate the uncertainty with respect to tax treatment and reduce costs for both taxpayers and the service. He has requested that tax practitioners, businesses, trade groups and others submit specific problems for consideration.

The IRS will focus on issues affecting a significant number of taxpayers where the appropriate tax treatment is uncertain, the problem has been repeatedly examined and factual determination is a major component. While the resulting guidance may vary, the IRS is most likely to issue it in the form of a revenue procedure that will permit taxpayers to adopt the recommended treatment on future tax returns.

Submissions must reach the LMSB office no later than February 28. Notice 2000-65 issued in December provides additional information on the IIR pilot and describes how to submit an issue.

For specifics on the IIR project, call Richard Druk of the LMSB Pre-filing and Technical Guidance Office at 202-283-8387. Details are also available on the IRS Web site at www.irs.gov .