Announcement 2010-9 by ProQuest


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									Part IV. Items of General Interest
Postponement of Certain                                         Correction of Publication                                      This Announcement discusses the poten-
Tax-Related Deadlines by                                                                                                       tial content of such a schedule and invites
                                                                   Accordingly, the publication of the final                   public comment on the Service’s proposed
Reason of a Federally                                           regulations (T.D. 9443), which were the                        approach. The schedule will require the
Declared Disaster or                                            subject of FR Doc. E9–767, is corrected                        annual disclosure of uncertain tax posi-
Terroristic or Military Action;                                 as follows:                                                    tions in the form of a concise description of
Correction                                                         On page 2370, column 3, in the pre-                         those positions and information about their
                                                                amble, under the paragraph heading “Ex-                        magnitude. The proposal does not require
Announcement 2010–8                                             planation of Revisions”, last paragraph of                     the taxpayer to disclose the taxpayer’s risk
                                                                the column, third through twelfth lines,                       assessment or tax reserve amounts, even
AGENCY: Internal Revenue Service                                the language “Example 9. Example 9,                            though the Service can compel the pro-
(IRS), Treasury.                                                which reflects current IRS practice, ex-                       duction of this information through a sum-
                                                                plains the impact of disaster relief on                        mons. United States v. Arthur Young, 465
ACTION: Correction to final regulations.                        installment agreement payments that be-                        U.S. 805, 815 (1984). While the Service
                                                                come due during the postponement period.                       intends to require the reporting of uncer-
SUMMARY: This document contains a
                                                                Example 9 explains that the affected tax-                      tain tax positions, the Service is propos-
correction to final regulations (T.D. 9443,
                                                                payer’s obligation to make installment                         ing to otherwise retain its existing pol-
2009–8 I.R.B. 564) that were published in
                                                                agreement payments is suspended during                         icy of restraint as described in Announce-
the Federal Register on Thursday, Jan-
                                                                the postponement period. Example 9 fur-                        ment 2002–63, 2002–2 C.B. 72, and IRM
uary 15, 2009 (74 FR 2370) relating to
                                                                ther explains that,” is corrected to read                      4.10.20.
postponement of certain tax-related dead-
                                                                “Example 8. Example 8, which reflects
lines either due to service in a combat
                                                                current IRS practice, explains the impact                      BACKGROUND
zone or due to a federally declared dis-
                                                                of disaster relief on installment agreement
aster. The regulations reflect changes in                                                                                      Uncertain Tax Positions
                                                                payments that become due during the post-
the law made by the Victims of Terrorism
                                                                ponement period. Example 8 explains that
Tax Relief Act of 2001, the Tax Extenders                                                                                          The United States federal income tax
                                                                the affected taxpayer’s obligation to make
and Alternative Minimum Tax Relief Act                                                                                         system relies on taxpayers to make a self-
                                                                installment agreement payments is sus-
of 2008 (TEAMTRA), and current IRS                                                                                             assessment of tax and to file the appropri-
                                                                pended during the postponement period.
practice.                                                                                                                      ate form of return that shows the facts upon
                                                                Example 8 further explains that,”.
                                                                                                                               which tax liability may be determined and
DATES: This correction is effective on De-                                                                                     assessed. Section 601.103 of the Proce-
                                                                                         LaNita Van Dyke,
cember 17, 2009, and is applicable on Jan-                                                                                     dure and Administration Regulations. To
                                                                                    Chief, Publications and
uary 15, 2009.                                                                                                                 discharge its obligation to fairly and uni-
                                                                                        Regulations Branch,
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